`
`IN THE UNITED STATES DISTRICT COURT
`IN AND FOR THE DISTRICT OF DELAWARE
`- - -
`
`CIVIL ACTION
`
`NO. 15-0031-RGA
`
`:::::::::
`
`BRADIUM TECHNOLOGIES LLC,
`Plaintiff,
`
`vs.
`MICROSOFT CORPORATION,
`Defendant.
`
`- - -
`Wilmington, Delaware
`Wednesday, February 3, 2016
`11:00 o'clock, a.m.
`- - -
`BEFORE: HONORABLE RICHARD G. ANDREWS, U.S.D.C.J.
`- - -
`
`APPEARANCES:
`
`PHILLIPS GOLDMAN & SPENCE, P.A.
`BY: DAVID A. BILSON, ESQ.
`
`-and-
`
`Valerie J. Gunning
`Official Court Reporter
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`Microsoft, Ex. 1035
`Microsoft v. Bradium, IPR2016-00449
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`APPEARANCES (Continued):
`
`2
`
`KENYON & KENYON LLP
`BY: MICHAEL N. ZACHARY, ESQ.
`
`-and-
`
`KENYON & KENYON LLP.
`BY: CHRIS J. COULSON, ESQ.
`(Palo Alto, California)
`
`-and-
`
`BRADIUM TECHNOLOGIES LLC
`BY: MICHAEL SHANRAHAN, ESQ.
`
`Counsel for Plaintiff
`
`RICHARDS, LAYTON & FINGER, P.A.
`BY: KELLY E. FARNAN, ESQ.
`
`-and-
`
`PERKINS COIE LLP
`BY: MATTHEW C. BERNSTEIN, ESQ.
`(San Diego, California)
`
`Counsel for Defendant
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`P R O C E E D I N G S
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`3
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`(REPORTER'S NOTE: The following conference was
`held in chambers, beginning at 11:00 a.m.)
`
`THE COURT: Good morning. Please be seated.
`This is Bradium Technologies versus Microsoft, Civil Action
`No. 15-31.
`
`I'm sorry. Mr. Coulson?
`MR. ZACHARY: No. I'm Michael Zachary, your
`
`Honor.
`
`THE COURT: I assume you're a member of the
`Delaware bar. I just have trouble remembering.
`MR. ZACHARY: No.
`MR. BILSON: David Bilson, your Honor.
`Phillips, Goldman & Spence.
`THE COURT: Oh, okay. Good morning, Mr. Bilson.
`MR. BILSON: Good morning.
`THE COURT: Who have you got with you here?
`MR. BILSON: With me today are Michael Zachary
`and Chris Coulson from Kenyon & Kenyon, and this is Michael
`Shanrahan, general counsel for Bradium.
`THE COURT: All right. Well, good morning to
`
`you all.
`
`Mr. Zachary.
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`MR. ZACHARY: Yes.
`THE COURT: Ms. Farnan?
`MS. FARNAN: Good morning, your Honor. I'm here
`today with Matthew Bernstein from Perkins Coie on behalf of
`Microsoft.
`
`THE COURT: All right. And is that in Seattle
`or San Francisco?
`MR. BERNSTEIN: San Diego, your Honor.
`THE COURT: Welcome to Delaware.
`MR. BERNSTEIN: Thank you, your Honor.
`THE COURT: All right. So I got the scheduling
`order and I appreciate that, notwithstanding the litigation
`that has already gone on, that you worked cooperatively to
`come up with essentially resolving almost everything.
`I would say that in regards to footnote No. 1,
`because I'm going to ask Mr. Bilson to resubmit this, just
`cross that out. If circumstances change and Microsoft
`thinks a stay is at some later point, nothing that has
`happened here or by this order has any effect on that, so
`you do what you need to do whether that point comes, if that
`point comes.
`
`Is there anything else in footnote 1 that I need
`to concern myself with?
`MR. BERNSTEIN: I don't think so, your Honor.
`MR. ZACHARY: No, your Honor.
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`THE COURT: Okay. In terms of page 3, there are
`two disputes. One is the number of requests for admission.
`I'm kind of inclined to go the with plaintiff's proposal
`because I think that generally requests for admission can
`serve to narrow down what's in dispute. So 15, not 25.
`In terms of the depositions, as I got from
`looking at this, there seem to be two issues, one relating
`to how much of the 70 hours is party, 30(b)(6) -- how much
`of it is the party and how much of it is 30(b)(6). And then
`there seems to be a second issue perhaps of how long the
`inventors can be deposed for.
`So I will start with the second one first. How
`many inventors are there?
`MR. ZACHARY: There are two inventors, your
`
`Honor.
`
`THE COURT: Are they in the U.S.?
`MR. ZACHARY: No, they are not. They are both
`overseas in Israel, and there are two issues. One is that
`it's a number of hours and the discussions and we're fine
`with it. Ten hours per inventor would be fine with the
`plaintiff. But as far as the 30(b)(1) aspect of the
`proposal, that's also an issue for us.
`THE COURT: Explain to me why.
`MR. ZACHARY: Primarily because we don't control
`the inventors, your Honor. One of them we don't have any
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`current representation of and don't have any relationship
`with him currently, so we cannot guarantee that he would
`appear pursuant to a 30(b)(1) notice.
`The other one --
`THE COURT: Well, so you're not complaining that
`they want to do it by 30(b)(1). You are just saying you're
`not guaranteeing that the person will respond to such a
`thing?
`
`MR. ZACHARY: Correct, your Honor.
`THE COURT: Okay.
`MR. ZACHARY: We don't know if he will or he
`
`won't.
`
`THE COURT: All right. So that does not -- so
`it does not seem like that's an issue, really. I don't know
`what that is, but that's -- I don't understand -- I guess I
`wouldn't understand.
`And Mr. Bernstein, tell me if you would be
`thinking differently here. I don't understand this to be a
`guarantee that the plaintiff can get the inventor to show
`up.
`
`MR. BERNSTEIN: Right. I mean, if they can't
`get him to show up, they can't use him in the case, they
`can't use him at trial. That's the way this plays out. I
`understand that's the case.
`THE COURT: All right.
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`MR. BERNSTEIN: That's for one of the inventors.
`THE COURT: And these inventors have names.
`Which inventor is that?
`MR. ZACHARY: Yoni Lavi is the one that is not
`affiliated with Bradium, the plaintiff, in any way, your
`Honor.
`
`THE COURT: Right. We'll just call him a free
`
`agent.
`
`one?
`
`MR. ZACHARY: Okay.
`THE COURT: And what's the name of the other
`
`MR. ZACHARY: Isaac Levanon.
`THE COURT: I take it this gentleman has some
`affiliation with Bradium?
`MR. ZACHARY: Some affiliation. I'm trying to
`narrow down what the affiliation is, but there's some
`affiliation.
`
`The intent is to bring him here for deposition,
`but I'm not in a position where I can guarantee that he
`would appear for deposition.
`MR. BERNSTEIN: So, your Honor, and I don't know
`if this is accurate or not, but he was represented to us
`previously as the co-owner and director of R&D of Bradium.
`That's what we were told previously.
`THE COURT: Well, so that's not going to be
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`resolved by me right now either. Right? And, of course, as
`I'm recalling -- okay. So, all right.
`So the second issue that counsel has identified,
`Mr. Zachary, that does not seem like an issue because I
`don't understand this to be promising anything really on
`behalf of either inventor at this point.
`And I am -- and so you say -- so actually,
`Mr. Bernstein, so it seems like your opponent said he is
`okay with ten hours. Why do you think I need to say 14?
`MR. BERNSTEIN: Well, so there's three
`patents-in-suit, and I think Mr. Zachary is going to say
`that they'd like to add a fourth patent. We are talking
`about 40 claims.
`There's also, your Honor, these -- the
`prosecution was a little bit unusual in that the inventors
`provided at least four declarations to one of the
`patents-in-suit, to one of the related patents, and these
`are -- I mean, they are pretty thick. There's a lot of
`exhibits. There's source code. There's talk about an
`embodying product and there's a lot to -- prior art
`invention.
`
`It's just a lot of topics, an unusually large
`number of topics, especially at least for three patents,
`and subsequently, there were four patents. There's a lot to
`do.
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`THE COURT: Do you have any response to that,
`
`Mr. Zachary?
`
`MR. ZACHARY: Yes, your Honor. I think ten
`hours should be enough for any individual testifying in
`their individual capacity to cover any number of topics.
`THE COURT: And do you then add a fourth
`
`patent?
`
`MR. ZACHARY: Yes. I was going to raise that
`at, when we got to the appropriate point. But a new
`patent was just issued yesterday to Bradium. It's in the
`same chain of patents, the same, or very similar
`specification.
`THE COURT: All right.
`MR. ZACHARY: Similar claims also.
`THE COURT: Are you going to oppose their
`
`amendment?
`
`MR. BERNSTEIN: I got a letter last night as I
`was going to sleep. I don't know what our position is on
`that at this time, your Honor.
`THE COURT: Okay. Well, on the whole, I would
`suggest you don't oppose it because I'm likely to grant
`it.
`
`MR. BERNSTEIN: Yes.
`THE COURT: But I understand you have not had
`time to think about it, and there may be details. I'm just
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`saying as a general matter, this seems like a perfectly
`appropriate thing to do, but I am not actually ruling on
`anything.
`
`MR. BERNSTEIN: Right. That's very helpful,
`
`your Honor.
`
`THE COURT: All right. And the inventor on this
`new patent, the same two inventors?
`MR. ZACHARY: Same, your Honor.
`THE COURT: All right. Well, I'm not normally
`inclined to give actually more than seven hours of inventor
`deposition, but what I'm going to say here is that I will
`give 14 hours for the gentleman who is affiliated with
`Bradium. The one who is not affiliated, unless he becomes
`affiliated, that's going to be limited to seven hours.
`And so partly I'm thinking that in regards to
`the inventor who is affiliated with Bradium, because I, in
`the normal course of events, the defendant wouldn't oppose
`them both, and so I think that kind of, since it seems like
`there may be a lot of difficulty in having the second
`inventor actually participate, that seems to be the reason
`that one might consider giving more time, and then the other
`thing is there are four patents.
`So I'm going to say 14. You know, if later
`developments, because I presume inventor depositions are
`probably a long ways off, but if later developments, for one
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`reason or another, make that too burdensome to the inventor,
`I would be willing to reconsider it in a more, with more of
`a factual basis than right here. But right now, 14 seems to
`me reasonable. Okay?
`MR. ZACHARY: Yes, your Honor.
`THE COURT: All right. So if we could modify
`the scheduling order to say which inventor is 14 and which
`inventor is seven, that would be good.
`In terms of the overall 30(b)(6) and overall
`hours of a party, let me think about this for a second.
`Plaintiff says 30 hours of 30(b)(6) is enough.
`
`Defendant --
`
`MR. BERNSTEIN: We can live with 30. We
`mentioned that to them before, 30 hours.
`THE COURT: Okay. So you're telling me this
`issue is resolved?
`MR. BERNSTEIN: Yes.
`THE COURT: Okay. Thank you. All right. So
`that resolves all the issues.
`MR. ZACHARY: One more on that, on the
`
`deposition.
`
`THE COURT: Oh.
`MR. ZACHARY: I don't know that it's still
`Microsoft's proposal that we be limited to 40 hours of a
`party or 42 hours.
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`MR. BERNSTEIN: No.
`THE COURT: I think they are agreeing with
`exactly what you have written here.
`MR. ZACHARY: Thank you.
`THE COURT: All right. So is the only other
`thing we need is dates? Actually, just let me ask, before I
`start doing dates, do I gather Microsoft either has or is
`planning, and I guess it's within the time limits to do so,
`to seek more IPRs on the patents in which IPRs were not
`instituted?
`
`MR. BERNSTEIN: We did. We filed two new IPRs
`January 7th or 8th, your Honor, so institution on those
`would be early July.
`THE COURT: All right. And you don't have to
`answer this if you tell me it's not appropriate to answer
`this, but why do you do these seriatim?
`MR. BERNSTEIN: The -- why did we --
`THE COURT: I mean, you filed one set of IPRs.
`You got one instituted and the other two not. Why don't you
`put all of your arguments in the first go-round?
`MR. BERNSTEIN: Well, I mean, I think the
`thinking that was that we did, but the PTAB gave us
`instructions, or in their order not instituting the two IPRs
`they gave us, or we believe they gave us instructions as to
`how we could do something differently, and so that's what we
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`did.
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`THE COURT: And so that is in some ways a reward
`for making the first IPR request very timely, is -- because
`isn't it the case that if a year passed from something,
`which I think maybe is the institution of the suit, then
`there's a time limit. Right?
`MR. BERNSTEIN: It's a year from service of the
`complaint, summons, your Honor. But, yes, I don't know if I
`would use the word "reward." I mean, I think just
`generally, at least my feeling on this issue has been the
`sooner you get the IPR done, the better.
`THE COURT: But if you had done this after seven
`months, their suggestions are not something you would be
`able to take up. Right?
`MR. BERNSTEIN: Correct.
`THE COURT: All right. And I take it the --
`when did you say this new patent was issued?
`MR. ZACHARY: Just yesterday. We provided
`notice of it yesterday.
`THE COURT: All right. I thought you said you
`provided notice to the amended suit. In any event, that's
`fine.
`
`MR. ZACHARY: May I suggest something, your
`
`Honor?
`
`THE COURT: Yes, sure.
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`MR. ZACHARY: With respect to the new patent and
`with respect to the Court's ruling of yesterday, here is our
`proposal. I think it will dovetail with the schedule that
`has already been proposed by the parties.
`We have sent notice, or Bradium sent notice to
`Microsoft concerning the new patent. It's kind of a
`standard notice without going into the details of it.
`If Microsoft does not respond the way the
`company has asked them to, then we would seek to add the
`patent to the case. I think we'll know that within 30 days.
`So my suggestion is that we file leave, perhaps consented
`to, to add the new patent within 30 days.
`In addition, with respect to the Court's ruling
`of yesterday on the motion to dismiss, there were a couple
`of items that I would like to address. One of them is that
`the Court did not mention leave to amend, and we would
`request leave to amend, and I would like to go into that in
`a little bit more detail.
`But our suggestion is if we're going to amend in
`30 days to add the new patent, that leave to amend with
`respect to the complaint on the other issues should also be
`on the same time frame, 30 days from now.
`THE COURT: All right. I take it, is
`Mr. Bernstein hearing this for the first time as I am?
`MR. ZACHARY: He is, your Honor. We just -- of
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`course, we just saw the Court's ruling yesterday.
`THE COURT: Okay. I understand we're all doing
`things at the last minute here.
`MR. ZACHARY: Yes.
`MR. BERNSTEIN: I mean if I could just quickly
`briefly respond.
`I mean, I think the adding of the patent is one
`issue. Your Honor has already provided some guidance as to
`whether we should oppose that.
`I think our, Microsoft's issue with amending to
`address other issues that came up in your order would be --
`I mean, we already briefed that issue. It has already been
`ruled on. What we don't want to have to do is spend the
`time and money re-briefing issues that we just, you know,
`briefed, and were ruled on.
`THE COURT: Well, so I presume that when someone
`says they seek leave to replead, they have additional
`factual allegations to put in, my impression -- you know, my
`impression is that for the most part, I thought plaintiff
`had probably used up all the factual allegations they had,
`but you never know.
`So what I'd say is, I don't think I have to
`decide anything right now on this and it gives you all an
`opportunity to discuss it. But if there are new -- but I
`won't say you can't seek leave to amend on that. You know,
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`it's worthwhile trying to make sure that in the end, I've
`gotten it right. And so I'm not really sure that if that is
`an issue and this being more briefing on it, and I don't
`express any opinion what the outcome might be, I don't
`think that I want to say you can't do that.
`And so to the extent -- and I'm certainly not
`suggesting like on the first thing you raised, suggesting
`that Microsoft not oppose -- you know, I think it's best for
`the parties to discuss this, but I'm not foreclosing
`anything. Okay?
`MR. ZACHARY: Thank you, your Honor.
`THE COURT: And in terms of 30 days, that seems
`
`fine to me.
`
`Microsoft.
`
`MR. BERNSTEIN: That's fine, your Honor, with
`
`MR. ZACHARY: Yes. The Court's ruling focused
`in on the issue of notice of the patents and specific
`intent, and though there were other issues addressed in
`Microsoft's motion, the Court's ruling appeared to be based
`upon that issue of intent and notice. And that is the issue
`we would focus on for purposes of any amendment.
`THE COURT: Okay.
`MR. ZACHARY: With respect to the issue of
`willfulness, you know, we are familiar with your Honor's
`prior rulings in that area. There seems to be some emerging
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`case law that strikes a middle ground between allowing
`willfulness allegations based solely upon post-complaint
`conduct versus not allowing that at all.
`THE COURT: Is there new case law emerging from
`the Federal Circuit?
`MR. ZACHARY: No.
`THE COURT: Okay.
`MR. ZACHARY: Not so far as I'm aware. But
`district courts, yes.
`THE COURT: Well, I wouldn't relitigate that
`unless you really have nothing better to do, because unless
`the Federal Circuit says differently, I'm not going to
`change my mind on that. Okay?
`MR. ZACHARY: I understand.
`THE COURT: So, you know, that's something that
`at the time when I first decided that, I gave that a lot of
`thought. So I'm not saying you can't do it, but I'm just
`saying I don't think that is likely to be very productive.
`MR. ZACHARY: Okay. Well, I will think about
`that. I have your Honor's comments in mind. I appreciate
`those.
`
`THE COURT: Okay.
`MR. ZACHARY: I'm not sure if the Court has
`previously addressed the case law that tries to strike a
`middle ground.
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`THE COURT: Okay.
`MR. ZACHARY: On that issue.
`THE COURT: Well, you make your best
`professional judgment, and, you know, if you think of
`something you should bring up, I will consider it.
`MR. ZACHARY: Thank you, your Honor.
`THE COURT: All right. So let's get the dates
`
`here.
`
`So the date I had in mind for the trial was
`January 8th of 2018.
`The date that I had in mind for the pretrial
`conference, December 22nd of 2017, at 9:00 a.m.
`And the date for the hearing on claim
`construction is January -- maybe you got this from my
`office. I don't know. It says January 16th on the
`submitted version, but I'd like to do it on January 20, 2017
`instead, at 9:00 a.m.
`MR. BERNSTEIN: The 20th?
`THE COURT: Yes. So hold on a minute.
`(Pause.)
`MS. FARNAN: The 16th was something we put in
`there, your Honor. We did not get it from your office.
`THE COURT: Okay. Is that a Monday?
`MS. FARNAN: That, I'm not sure.
`THE COURT: I will check it.
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`Microsoft, Ex. 1035
`Microsoft v. Bradium, IPR2016-00449
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`(Pause.)
`THE COURT: All right. The 16th, part of that
`is it's a Federal holiday, Ms. Farnan.
`MS. FARNAN: I apologize, your Honor.
`THE COURT: All right. Let me just check and
`see why we picked the 20th.
`(Pause.)
`THE COURT: You know, that's Inauguration Day.
`I'm not going to be invited, but it strikes me maybe that's
`not the best day. Let me see what else I have there.
`Why don't we do -- oh, I see why we're doing it
`on that day. I'm perfectly willing to do it on Inauguration
`Day, but if any of you think that you might have other
`plans, or just think it's important to watch TV that day,
`I'm not wedded to it.
`MR. BERNSTEIN: January 20th is fine with me,
`
`your Honor.
`
`MR. ZACHARY: That's fine with us, your Honor.
`THE COURT: All right. January 20th at
`9:00 a.m. then.
`MR. ZACHARY: All right.
`THE COURT: All right. And so I think that's
`all the dates.
`Is there anything else you want to discuss while
`
`you're here?
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`Microsoft, Ex. 1035
`Microsoft v. Bradium, IPR2016-00449
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`MR. ZACHARY: I will check my notes.
`THE COURT: Mr. Zachary?
`MR. ZACHARY: I think that's it for us, your
`
`Honor.
`
`THE COURT: Mr. Bernstein?
`MR. BERNSTEIN: Nothing else, your Honor.
`THE COURT: Okay. Well, thank you very much. I
`will look forward to -- on well, the next time I hear from
`you. All right?
`(Counsel respond, "Thank you, your Honor.")
`(Conference concluded at 11:27 a.m.)
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`Microsoft, Ex. 1035
`Microsoft v. Bradium, IPR2016-00449
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`