`IPR of U.S. Patent No. 8,225,408
`
`Filed on behalf of Petitioner
`By:
`Joseph J. Richetti
`Kevin E. Paganini
`Bryan Cave LLP
`1290 Avenue of the Americas
`New York, NY 10104
`Tel: (212) 541-2000
`Fax: (212) 541-4630
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`PROOFPOINT, INC. AND
`ARMORIZE TECHNOLOGIES, INC.
`Petitioner
`
`v.
`
`FINJAN, INC.
`Patent Owner
`
`IPR2016-00967
`U.S. Patent No. 8,225,408
`
`MOTION FOR JOINDER UNDER
`35 U.S.C. § 315(c) AND 37 C.F.R. §§ 42.22 AND 42.122(b)
`TO INTER PARTES REVIEW OF IPR2015-02001
`
`
`
`IPR2016-00967
`IPR of U.S. Patent No. 8,225,408
`
`TABLE OF CONTENTS
`
`I.
`
`II.
`
`STATEMENT OF PRECISE RELIEF REQUESTED .............................1
`
`STATEMENT OF MATERIAL FACTS....................................................2
`
`III.
`
`STATEMENT OF REASONS FOR RELIEF REQUESTED..................5
`
`A.
`
`B.
`
`C.
`
`Legal Standard.......................................................................................5
`
`Petitioner’s Motion for Joinder is Timely.............................................5
`
`Each Factor Weighs in Favor of Joinder...............................................6
`
`1.
`
`2.
`
`3.
`
`Joinder is Appropriate and Petitioner Presents No New
`Grounds.......................................................................................6
`
`Joinder Will Not Negatively Impact the PAN IPR Trial
`Schedule......................................................................................7
`
`Procedures to Simplify Briefing and Discovery.........................9
`
`D. Without Joinder, Petitioner is prejudiced............................................10
`
`E.
`
`Joinder Will Not Prejudice the Parties to the Consolidated PAN
`IPRs .....................................................................................................11
`
`IV. CONCLUSION..............................................................................................11
`
`
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`IPR2016-00967
`IPR of U.S. Patent No. 8,225,408
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`I.
`
`STATEMENT OF PRECISE RELIEF REQUESTED
`
`Proofpoint, Inc. and Armorize Technologies, Inc. (“Petitioner”) respectfully
`
`submits this Motion for Joinder, together with a petition (the “Proofpoint Petition”)
`
`for Inter Partes Review of U.S. Patent No. 8,225,408 (the “‘408 patent”) filed con-
`
`temporaneously herewith. Pursuant to 35 U.S.C. § 315(c) and 37 C.F.R. §
`
`42.122(b), Petitioner requests institution of an inter partes review and joinder with
`
`IPR2015-02001 filed by Palo Alto Networks, Inc. (“PAN”), which was instituted
`
`and consolidated with PAN’s IPR2016-00157 on March 29, 2016 concerning the
`
`same ‘408 patent (together the “Consolidated PAN IPRs”). The Proofpoint Peti-
`
`tion duplicates the grounds in IPR2015-02001.
`
`Petitioner timely filed the
`
`Proofpoint Petition and this motion within one month of the institution of the PAN
`
`IPR. 37 C.F.R. § 42.122(b). Petitioner is also concurrently filing a second petition
`
`duplicating the grounds in IPR2016-00157 together with a motion requesting join-
`
`der in the Consolidated PAN IPRs.
`
`Joinder will efficiently resolve the challenges to the ‘408 patent in the Con-
`
`solidated PAN IPRs, and will neither impact the substantive issues or schedule in
`
`those proceedings, nor prejudice the parties. The Proofpoint Petition raises the
`
`same grounds of unpatentability for which PAN’s IPR2015-02001 was instituted,
`
`challenges the same claims, and relies on the same prior art, arguments and evi-
`
`dence presented by PAN in IPR2015-02001. Similarly, Proofpoint’s second peti-
`
`1
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`
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`IPR2016-00967
`IPR of U.S. Patent No. 8,225,408
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`tion concerning the ‘408 patent raises the same grounds of unpatentability for
`
`which IPR2016-00157 was instituted, challenges the same claims, and relies on the
`
`same prior art, arguments and evidence presented by PAN in IPR2016-00157. In
`
`addition, Petitioner explicitly agrees to consolidated discovery and briefing as de-
`
`scribed below, and is willing to accept a limited role with PAN’s counsel acting as
`
`the lead counsel as long as PAN remains in the proceedings.1 Accordingly, Peti-
`
`tioner submits that joinder is appropriate because it will not prejudice the parties or
`
`impact the substantive issues and schedule in the Consolidated PAN IPRs, while
`
`efficiently resolving the question of the ‘408 patent’s validity based on the institut-
`
`ed grounds in those consolidated proceedings.
`
`II.
`
`STATEMENT OF MATERIAL FACTS
`
`1. The ‘408 patent is entitled “Method and system for adaptive rule-
`
`based content scanners” and lists Moshe Rubin et al. as inventors. The ‘408 patent
`
`1 Petitioner notes that on April 27, 2016, Blue Coat Systems, Inc. (“Blue Coat”)
`
`also filed a motion requesting joinder to the PAN IPRs (IPR2016-00955 and 2016-
`
`00956). In the event that Blue Coat’s motion for joinder are granted, Petitioner
`
`agrees to the same procedures for simplified briefing and discovery discussed here-
`
`in and, in the event that PAN settles with Patent Owner, Petitioner agrees to work
`
`with Blue Coat to determine which counsel will replace PAN’s counsel as the lead
`
`counsel in the proceedings.
`
`2
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`
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`IPR2016-00967
`IPR of U.S. Patent No. 8,225,408
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`issued on July 17, 2012. Finjan, Inc. (the “Patent Owner”) is believed to have all
`
`rights, title, and interest in ‘408 patent.
`
`2. On December 16, 2013, Patent Owner filed a civil action asserting the
`
`‘408 patent, along with other patents, against Proofpoint, Inc. and Armorize Tech-
`
`nologies, Inc. in Civil Action No. 3:13-cv-05808. A jury trial concerning the pa-
`
`tents that remain in this suit is currently scheduled for June 13, 2016.
`
`3. On November 4, 2014, Patent Owner filed a civil action asserting the
`
`‘408 patent, along with other patents, against PAN in Civil Action No. 3:14-cv-
`
`04908.
`
`4. On September 30, 2015, PAN filed a petition for inter partes review
`
`requesting cancellation of claims 1, 9, 22, 23, 29, and 35 of the ‘408 patent (the
`
`“PAN Petition”), which was subsequently assigned Case No. IPR2015-02001.
`
`5. On November 6, 2015, PAN filed a petition for inter partes review
`
`requesting cancellation of claims 1, 3-7, 9, 12-16, and 18-21 of the ‘408 patent,
`
`which was subsequently assigned Case No. IPR2016-00157.2
`
`2 Petitioner notes that PAN’s petition in IPR2016-00157 initially omitted claims 1
`
`and 9 from the specified challenge. The Board, however, indicated that claims 1
`
`and 9 were also subject to review due to the dependence of the listed challenged
`
`claims on claims 1 and 9. Palo Alto Networks, Inc. v. Finjan, Inc., IPR2016-
`
`00157, paper 3 at 1 (PTAB November 17, 2015).
`
`3
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`
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`IPR2016-00967
`IPR of U.S. Patent No. 8,225,408
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`6. On March 29, 2016, the Board instituted inter partes review in Case
`
`Nos. IPR2015-02001 and IPR2016-00157, finding that a reasonable likelihood ex-
`
`isted that based upon its petitions PAN would prevail in showing the unpatentabil-
`
`ity of claims 1, 3–7, 9, 12–16, 18-23, 29, and 35 of the ‘408 patent. As part of the
`
`order instituting trial, the Board Consolidated Case Nos. IPR2015-02001 and
`
`IPR2016-00157.
`
`7. On April 12, 2016, Patent Owner filed a Request for Rehearing claim-
`
`ing that the Board overlooked arguments and requesting that the Board reverse its
`
`decision to institute trial as to claims 1, 3–7, 9, 12–16, 18-23, 29, and 35 of the
`
`‘408 patent. No decision has been rendered on Patent Owner’s Request for Re-
`
`hearing.
`
`8. On April 27, 2016, Blue Coat filed petitions and a motion for joinder
`
`to join IPR2015-02001 and IPR2016-00157. Blue Coat’s petitions have been as-
`
`signed Case Nos. IPR2016-00955 and 2016-00956 (the “Blue Coat IPRs”). Like
`
`Proofpoint, Blue Coat submits that its petitions are “substantially identical to the
`
`corresponding instituted grounds of the Consolidated PAN IPRs.” Blue Coat Sys-
`
`tems, Inc. v. Finjan, Inc., IPR2015-00955, paper 3 at 2 (PTAB April 27, 2016). No
`
`decision has been rendered in the Blue Coat IPRs.
`
`4
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`IPR2016-00967
`IPR of U.S. Patent No. 8,225,408
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`III.
`
`STATEMENT OF REASONS FOR RELIEF REQUESTED
`
`A. Legal Standard
`
`The Board has the authority under 35 U.S.C. § 315(c) to join a properly filed
`
`inter partes review petition to an instituted inter partes review proceeding. See 35
`
`U.S.C. § 315(c). Any request for joinder must be filed no later than one month af-
`
`ter the institution date of any inter partes review for which joinder is requested.
`
`See 37 C.F.R. § 42.122(b).
`
`In deciding whether to exercise its discretion, the
`
`Board considers factors including: (1) the reasons why joinder is appropriate; (2)
`
`whether the new petition presents any new grounds of unpatentability; (3) what
`
`impact, if any, joinder would have on the trial schedule for the existing review; and
`
`(4) how briefing and discovery may be simplified. See Macronix Int’l Co. v. Span-
`
`sion, IPR2014-00898, paper 13, at 4 (PTAB Aug. 13, 2014) (citing Kyocera Cor-
`
`poration v. Softview LLC, IPR2013-00004, paper 15 at 4 (PTAB April 24, 2013));
`
`Perfect World Entertainment, Inc. v. Uniloc USA, Inc., et al., IPR2015-01026, pa-
`
`per 10 at 4 (PTAB Aug. 3, 2015); Mylan Pharmaceuticals Inc. v. Novartis AG, et
`
`al., IPR2015-00265, paper 17 at 4 (PTAB April 10, 2015); Ciena Corp., et al. v.
`
`Capella Photonics, Inc., IPR2015-01958, paper 11 (PTAB April 1, 2016).
`
`B. Petitioner’s Motion for Joinder is Timely
`
`This Motion for Joinder is timely because it is filed within one month of the
`
`March 29, 2016 institution decision in the Consolidated PAN IPRs which includes
`
`IPR2015-02001. See 37 C.F.R. § 42.122(b). The one-year bar set forth in 37
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`5
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`IPR2016-00967
`IPR of U.S. Patent No. 8,225,408
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`C.F.R. § 42.101(b) does not apply when a petition is filed concurrently with a mo-
`
`tion for joinder, as is currently the case here with the Proofpoint Petition. Id.
`
`C. Each Factor Weighs in Favor of Joinder
`
`Each of the four factors to be considered by the Board in ruling on this mo-
`
`tion weighs in favor of joinder. As explained in further detail below, joinder is
`
`proper because the Proofpoint Petition does not present any new grounds of un-
`
`patentability, is substantively identical to the PAN Petition, will have minimal im-
`
`pact, if any, on the trial schedule, briefing and discovery in the Consolidated PAN
`
`IPRs, and allows all issues to be resolved in a single proceeding before the Board.
`
`Petitioner further agrees to take on a limited role in the proceeding.
`
`1. Joinder is Appropriate and Petitioner Presents No New
`Grounds
`
`Joinder is appropriate because the Proofpoint Petition involves the same pa-
`
`tent, challenges the same claims, and relies on the same prior art, arguments and
`
`expert declaration presented in IPR2015-02001.3 Importantly, the Proofpoint Peti-
`
`tion does not raise any new grounds of unpatentability. Further, the Proofpoint Pe-
`
`tition relies on the same grounds from the PAN Petition on which the Board insti-
`
`tuted review on March 29, 2016, and is substantively identical to the PAN Petition.
`
`3 The Proofpoint Petition is submitted with the same Exhibits as those submitted
`
`with IPR2015-02001.
`
`6
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`IPR2016-00967
`IPR of U.S. Patent No. 8,225,408
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`Indeed, the substantive challenges presented in the Proofpoint Petition are copied
`
`verbatim from the PAN Petition and rely on the same supporting expert declara-
`
`tion. The primary differences between the Proofpoint Petition and the PAN Peti-
`
`tion relate to removal of certain portions of the introduction in the PAN petition,
`
`minor formalities associated with the parties involved with filing the petitions and
`
`references to related proceedings. The Proofpoint Petition presents the same ar-
`
`guments, expert declaration, and prior art presented in the PAN Petition; it does not
`
`add to or alter any argument that has already been considered by the Board, nor
`
`does it seek to expand the grounds of unpatentability that the Board has already in-
`
`stituted. Proofpoint’s second petition, which is filed concurrently herewith and
`
`which similarly duplicates PAN’s petition in IPR2016-00157, also does not add to
`
`or alter any argument that has already been considered by the Board, nor does it
`
`seek to expand the grounds of unpatentability that the Board has already instituted
`
`in that IPR, which has been consolidated with IPR2015-02001. Accordingly, join-
`
`der is appropriate and allows the Board to efficiently resolve the instituted grounds
`
`in a single proceeding.
`
`2. Joinder Will Not Negatively Impact the PAN IPR Trial
`Schedule
`
`35 U.S.C. § 316(a)(11) provides that “the final determination in an inter
`
`partes review be issued not later than one year after the date on which the Director
`
`notices the institution of a review.” See also 37 C.F.R. § 42.100(c). Joinder in this
`
`7
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`IPR2016-00967
`IPR of U.S. Patent No. 8,225,408
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`case will not impact this mandate and will not even require modification of the ex-
`
`isting scheduling order. See, IPR2015-02001, paper 8. As explained above, the
`
`Proofpoint Petition is substantively identical with respect to the instituted grounds
`
`contained in the PAN Petition. Thus, the Preliminary Response and Request for
`
`Rehearing already filed by Patent Owner in IPR2015-02001 address any and all
`
`issues in the Proofpoint Petition. See IPR2015-02001, papers 6 and 9. Further-
`
`more, there are no new issues for Patent Owner to address and Patent Owner will
`
`not be required to file additional responses or arguments. Consequently, the Patent
`
`Owner response will also not be impacted; joining Petitioner to the Consolidated
`
`PAN IPRs will not require any additional analysis by Patent Owner beyond what
`
`they will already undertake to respond to the PAN Petition. Also, since the
`
`Proofpoint Petition relies on the same expert declaration, no additional depositions
`
`are needed for the proposed joined proceeding. Proofpoint’s second petition,
`
`which is filed concurrently herewith and which is substantially identical with re-
`
`spect to the instituted grounds contained in PAN’s petition in IPR2016-00157, also
`
`does not raise any new issues or require additional responses, arguments, analysis
`
`or depositions in the proposed joined proceeding with the Consolidated PAN IPRs.
`
`For efficiency’s sake, if joined, Petitioner further agrees to consolidated discovery
`
`with PAN’s counsel acting as the lead counsel so long as PAN remains in the pro-
`
`8
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`IPR2016-00967
`IPR of U.S. Patent No. 8,225,408
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`ceeding.4
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`For at least the reasons set forth above, there is no reason to delay or alter
`
`the schedule already present in the Consolidated PAN IPRs, and Petitioner explic-
`
`itly consents to this schedule. Accordingly, joinder of these proceedings will not
`
`negatively impact the trial schedule of the Consolidated PAN IPRs.
`
`3. Procedures to Simplify Briefing and Discovery
`
`As discussed above, Petitioner offers no new grounds for invalidity and Peti-
`
`tioner does not anticipate that its presence will introduce any additional arguments,
`
`briefing or need for discovery. As long as PAN remains an active participant in
`
`the Consolidated PAN IPRs, Petitioner is willing to accept a limited role and agree
`
`to: (1) consolidate filings with PAN; (2) refrain from raising any new grounds not
`
`already considered by the Board in the Consolidated PAN IPRs; (3) be bound by
`
`any agreement between Patent Owner and PAN concerning discovery and/or depo-
`
`sitions; (4) limit any direct, cross-examination or redirect time beyond that permit-
`
`ted for PAN alone under either 37 C.F.R. § 42.53 or any agreement between PAN
`
`and the Patent Owner, such that Petitioner’s participation in the Consolidated PAN
`
`IPRs does not result in any additional time being required for any deposition; and
`
`4 As referenced in fn. 1, in the event that Blue Coat is joined and PAN settles with
`
`Patent Owner, Petitioner agrees to work with Blue Coat to determine which coun-
`
`sel will replace PAN’s counsel as the lead counsel in the proceedings.
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`9
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`IPR2016-00967
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`(5) limit any presentation at oral hearing to unused time previously allocated to
`
`PAN.5 By accepting this limited role, both the Board and parties will be able to
`
`comply with the existing schedule in the Consolidated PAN IPRs and avoid any
`
`duplication of efforts. The Board has consistently granted joinder motions allow-
`
`ing Petitioners to take a similar role as that proposed by Petitioner in this proceed-
`
`ing.6 Accordingly, Petitioner requests that the Board grant Petitioner’s motion for
`
`joinder, particularly in light of the foregoing procedural safeguards and limited role
`
`that Petitioner is willing to accept in this proceeding.
`
`D. Without Joinder, Petitioner is prejudiced
`
`Petitioner will be prejudiced if it is not permitted to join in the Consolidated
`
`5 In the event that Blue Coat’s motion for joinder is also granted, Petitioner agrees
`
`to the same procedures for simplified briefing and discovery or other reasonable
`
`conditions for the conduct of the combined, joined proceedings that are deemed
`
`appropriate by the Board.
`
`6 See, e.g., Ciena Corp., et al. v. Capella Photonics, Inc., IPR2015-01958, paper 11
`
`(PTAB April 1, 2016); Sony Corp., et al. v. Memory Integrity, LLC, IPR2015-
`
`01376, paper 12 at 16-20 (PTAB Sept. 29, 2015); Ciena Corp., et al. v. Capella
`
`Photonics, Inc., IPR2015-00894, paper 12 (PTAB Sept. 22, 2015); Dell Inc. v.
`
`Network-1 Security Solutions, Inc., IPR2013-00385, paper 17 (PTAB July 29,
`
`2013).
`
`10
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`
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`IPR2016-00967
`IPR of U.S. Patent No. 8,225,408
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`PAN IPRs. Patent Owner has asserted the ‘408 patent against Petitioner in a pend-
`
`ing litigation and the one-year statutory bar for filing an IPR by Petitioner has been
`
`exhausted. Although the issue of Petitioner’s alleged infringement of the ‘408 pa-
`
`tent is no longer being pursued by Patent Owner in that litigation, Petitioner should
`
`be permitted to join the pending IPR to participate in proceedings affecting the
`
`claims of a patent asserted against it, and thereby allowed to continue the proceed-
`
`ings should PAN and Patent Owner settle under 37 C.F.R. § 42.74 before a final
`
`written decision is issued.
`
`E.
`
`Joinder Will Not Prejudice the Parties to the Consolidated PAN
`IPRs
`
`Permitting joinder will not prejudice PAN or Patent Owner. It is Petitioner’s
`
`understanding that PAN does not intend to oppose this joinder motion. Also, Pa-
`
`tent Owner is not prejudiced as all of the issues raised by Petitioner are already
`
`known to Patent Owner. Further, Patent Owner is not expected to incur any addi-
`
`tional burden as a result of this joinder. This is particularly true in light of the lim-
`
`ited role that Petitioner proposes to undertake in the joined proceedings. Joinder
`
`will allow the Board to address the same patent validity questions in a single
`
`proceeding within a statutory deadline without adding costs or burdens on any of
`
`the parties.
`
`IV. CONCLUSION
`Based on the factors outlined above, Petitioner requests the Board grant the
`
`11
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`IPR2016-00967
`IPR of U.S. Patent No. 8,225,408
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`Proofpoint Petition for Inter Partes Review of U.S. Patent No. 8,225,408 and grant
`
`joinder with the Palo Alto Networks, Inc. v. Finjan, Inc., IPR2015-02001 proceed-
`
`ing.
`
`Date: April 29, 2016
`
`Respectfully submitted,
`
`By: /Joseph J. Richetti, Reg. No. 47024/
`Joseph J. Richetti (Reg. No. 47,024)
`BRYAN CAVE LLP
`1290 Avenue of the Americas
`New York, NY 10104
`General Tel: (212) 541-2000
`Fax: (212) 541-4630
`Email: joe.richetti@bryancave.com
`IPR2016-00967@bryancave.com
`PTAB-NY@bryancave.com
`
`Attorneys for Petitioner – Proofpoint, Inc. and
`Armorize Technologies, Inc.
`
`12
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`IPR2016-00967
`IPR of U.S. Patent No. 8,225,408
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`CERTIFICATION OF SERVICE (37 C.F.R. §§ 42.6(e), 42.105(a))
`
`The undersigned hereby certifies that the above-captioned “MOTION FOR
`
`JOINDER UNDER 35 U.S.C. § 315(c) AND 37 C.F.R. §§ 42.22 AND 42.122(b)
`
`TO INTER PARTES REVIEW OF IPR2015-02001” was served in its entirety on
`
`April 29, 2016, upon the following parties via FedEx:
`
`Attorney of Record for U.S. Patent No. 8,225,408:
`
`Dawn-Marie Bey
`Marc Berger
`Christopher Cotropia
`Sang Kim
`Julie Mar-Spinola
`BEY & COTROPIA PLLC
`213 Bayly Court
`Richmond, VA 23229
`
`Counsel for Patent Owner in IPR2015-02001 and IPR2016-00157:
`
`James Hannah
`Paul J. Andre
`Kramer Levin Naftalis & Frankel LLP
`990 Marsh Road
`Menlo Park, CA 94025
`jhannah@kramerlevin.com
`
`Jeffrey H. Price
`Benu C. Wells
`Kramer Levin Naftalis & Frankel LLP
`1177 Avenue of the Americas
`New York, NY 10036
`jprice@kramerlevin.com
`
`Michael Kim
`Finjan Inc.
`2000 University Ave., Ste. 600
`E. Palo Alto, CA 94303
`mkim@finjan.com
`
`
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`IPR2016-00967
`IPR of U.S. Patent No. 8,225,408
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`Counsel for Petitioner in IPR2015-02001 and IPR2016-00157:
`
`Orion Armon
`Brian Eutermoser
`COOLEY LLP
`380 Interlocken Crescent, Suite 900
`Broomfield, Colorado 80021
`oarmon@cooley.com
`beutermoser@cooley.com
`zpatdcdocketing@cooley.com
`
`Christopher Max Colice
`COOLEY LLP
`500 Boylston Street, 14th Floor
`Boston, Massachusetts 02116-3736
`mcolice@cooley.com
`zpatdcdocketing@cooley.com
`
`Mathew I. Kreeger
`Matthew Chivvis
`MORRISON & FOERSTER LLP
`425 Market Street
`San Francisco, CA 94105
`MKreeger@mofo.com
`MChivvis@mofo.com
`FinjanPANMofoTeam@mofo.com
`
`Jennifer Volk-Fortier
`COOLEY LLP
`One Freedom Square
`Reston Town Center
`11951 Freedom Drive
`Reston, Virginia 20194
`jvolkfortier@cooley.com
`zpatdcdocketing@cooley.com
`
`Orion Armon
`Christopher Max Colice
`Jennifer Volk-Fortier
`Brian Eutermoser
`COOLEY LLP
`ATTN: Patent Group
`1299 Pennsylvania Ave., NW, Suite 700
`Washington, DC 20004
`zPaloAltoNetworksIPR@cooley.com
`
`Jonathan Bockman
`MORRISON & FOERSTER LLP
`1650 Tysons Boulevard
`McLean, VA 22101
`JBockmanr@mofo.com
`FinjanPANMofoTeam@mofo.com
`
`
`
`IPR2016-00967
`IPR of U.S. Patent No. 8,225,408
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`Date: April 29, 2016
`
`Respectfully submitted,
`
`By: /Joseph J. Richetti, Reg. No. 47024/
`Joseph J. Richetti (Reg. No. 47,024)
`Lead Attorney for Petitioner
`BRYAN CAVE LLP
`1290 Avenue of the Americas
`New York, NY 10104
`Direct Tel: (212) 541-1092
`Email: joe.richetti@bryancave.com
`IPR2016-00967@bryancave.com
`PTAB-NY@bryancave.com
`
`Attorney for Petitioner – Proofpoint, Inc.
`and Armorize Technologies, Inc.