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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`- - - - - - - - - - - - - - -x
` :
`FORD MOTOR COMPANY, :
` :
` Petitioner, :
` :
` vs. : Case IPR2016-01012
` : Case IPR2016-01013
`TRILOGY DEVELOPMENT GROUP, :
`INC., :
` :
` Patent Owner. :
` :
`- - - - - - - - - - - - - - -x
` Washington, D.C.
` Tuesday, October 11, 2016
`
` The Patent and Trademark Appeal Board
`telephonic conference came on to be heard before
`Judge James Arpin, Judge Howard Blakenship and
`Judge William Fink, before Denise M. Brunet, RPR,
`Notary Public, in and for the District of
`Columbia, commencing at 1:00 p.m.
` Veritext Legal Solutions
` Mid-Atlantic Region
` 1250 Eye Street NW - Suite 350
` Washington, D.C. 20005
`
`Veritext Legal Solutions
`215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
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`0001
`
`Trilogy 2011
`Ford v. Trilogy
`IPR2016-01013
`
`

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` A P P E A R A N C E S
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`O n b e h a l f o f t h e P e t i t i o n e r :
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` C H R I S T O P H E R S M I T H , E S Q U I R E
` J O H N L e R O Y , E S Q U I R E
` B r o o k s K u s h m a n
` 1 0 0 0 T o w n C e n t e r
` 2 2 n d F l o o r
` S o u t h f i e l d , M i c h i g a n 4 8 0 7 5
` ( 2 4 8 ) 3 5 8 - 4 4 0 0
` c s m i t h @ b r o o k s k u s h m a n . c o m
`
`O n b e h a l f o f t h e P a t e n t O w n e r :
`
` R O B E R T G . S T E R N E , E S Q U I R E
` J O S E P H E . M U T S C H E L K N A U S , E S Q U I R E
` S A L V A D O R M . B E Z O S , E S Q U I R E
` J O N A T H A N T U M I N A R O , E S Q U I R E
` S t e r n e K e s s l e r G o l d s t e i n & F o x
` 1 1 0 0 N e w Y o r k A v e n u e , N o r t h w e s t
` S u i t e 6 0 0
` W a s h i n g t o n , D . C . 2 0 0 0 5
` ( 2 0 2 ) 3 7 1 - 2 6 0 0
` r s t e r n e @ s k g f . c o m
`
` * * * * *
`
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` P R O C E E D I N G S
`
` JUDGE ARPIN: Good Afternoon. This is
`
`Judge Arpin. I'm joined in this call by Judges
`
`Blakenship and Fink. This is a conference call
`
`for two cases, IPR 2016-01012 and IPR 2016-01013.
`
`I'm going to begin with roll call.
`
` Who do I have on the line?
`
` Petitioner, please.
`
` MR. SMITH: For the Petitioner Ford
`
`Motor Company it's Christopher Smith and John
`
`LeRoy.
`
` JUDGE ARPIN: Thank you. Who do we
`
`have on the call for the Patent Owner, please?
`
` MR. STERNE: Good afternoon, Your
`
`Honor. This is Robert Sterne for Patent Owner
`
`Trilogy Development Group and with me on the call
`
`are my colleagues who are of record, Jonathan
`
`Tuminaro, Sal Bezos and Joseph Mutschelknaus.
`
` JUDGE ARPIN: Thank you. If I heard
`
`correctly, we have a court reporter on the line.
`
`Is the court reporter provided by Patent Owner or
`
`by Petitioner?
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` MR. STERNE: Your Honor, this is Robert
`
`Sterne again. The court reporter is being
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`provided by Patent Owner and we have indicated to
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`the reporter to provide you with a transcript in
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`very short due course time.
`
` JUDGE ARPIN: Great. All right.
`
`Because we have a court reporter on the line, I
`
`want both parties to take the lead from what
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`Mr. Sterne has just done, that is, identify
`
`himself before he begins speaking. This should
`
`allow the court reporter to know who is speaking
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`without the court reporter having to interrupt and
`
`ask.
`
` I now address the court reporter. If
`
`you do need to interrupt, please keep your
`
`interruptions as short and to a minimum, whatever
`
`is the minimum that you can get by and ensure an
`
`accurate transcript.
`
` I assume that you will be providing the
`
`transcript to the Patent Owner. Is that correct,
`
`Court Reporter?
`
` THE COURT REPORTER: Yes, sir.
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` JUDGE ARPIN: I would ask, Mr. Sterne,
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`then, to -- before the copy of the transcript is
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`filed with the Board to please provide a copy to
`
`the Petitioner so that any errata can be resolved
`
`before the filing.
`
` Is that understood by both parties?
`
` Patent Owner?
`
` MR. STERNE: Yes. This is Robert
`
`Sterne. Yes. We understand that, Your Honor.
`
` JUDGE ARPIN: Petitioner?
`
` MR. SMITH: This is Christopher Smith
`
`and, yes, we understand, Your Honor.
`
` JUDGE ARPIN: Thank you very much.
`
` Before we begin, there was a little bit
`
`of confusion about the proper procedure for
`
`requesting a conference with the Board and I'd
`
`just like to take a moment to go over some
`
`guidelines that certainly will apply in this case
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`and, in my experience, apply in most cases before
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`the Board.
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` I know that the trial practice guide
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`doesn't specifically require that there be a
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`conference before any calls, but I think that the
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`parties will find that most judges on the Board
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`will require that there is a conference before any
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`calls or e-mails are sent to the Board. So both
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`parties here should take it as a rule that they
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`shall confer before contacting the Board.
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` Second, because we have judges in
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`different time zones, because we have parties with
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`counsel in different time zones, when the parties
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`confer they should send to the Board alternative
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`dates and times identified by time zone as to when
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`they are available for a call.
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` Third, except in the very limited
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`circumstances that are identified in the trial
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`practice guide, there should be no ex-parte
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`communications with the Board. And that's also
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`set forth in our Rule 37 CFR 42.5(d).
`
` And the last piece of guidance that I'd
`
`like to give to the parties before we begin
`
`discussing the substance of the call today is that
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`either party when sending an e-mail to the Board
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`should copy all of the counsel of record of the
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`opposing party. I said should. That is a shall.
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`They shall inform or they shall copy all of the
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`opposing counsel of record. We want these
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`communications to be completely transparent and we
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`want everybody to know what's going on.
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` I said that was the last piece of
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`guidance. There is one other. The e-mails to the
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`Board should be short and sweet. They should not
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`be seen by either party as an opportunity to
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`provide briefing or explanation to the Board.
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`Please just tell us when you're available to talk,
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`that you've conferred and you haven't been able to
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`reach agreement, and the basic substance of the
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`matter that you wish to discuss with us.
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` Do both parties understand that?
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` Petitioner?
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` MR. SMITH: This is Christopher Smith.
`
`Yes, the Petitioner understands.
`
` JUDGE ARPIN: Patent Owner?
`
` MR. STERNE: Yes, Your Honor. This is
`
`Robert Sterne. We understand. Thank you for that
`
`guidance.
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` JUDGE ARPIN: Thank you very much,
`
`gentlemen.
`
` With that, Petitioner requested this
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`call so I'm going to give Petitioner the
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`opportunity to speak first. I understand the
`
`issue here is a request to file a reply to the
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`preliminary response.
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` When you address these issues,
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`Petitioner, I would like you to focus on two
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`issues. First, we are now a month away from the
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`statutory deadline to institute in these cases.
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`Please address how we will work within that time,
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`which cannot be extended, if we are to grant you
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`any kind of reply.
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` And, secondly, because the requirement
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`that IPRs be based on the written publication is
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`foundational to IPRs, you'll need to explain why
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`there is something in the preliminary response
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`which you couldn't have addressed in the petition.
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` With that, Petitioner, you may state
`
`your reasons for your request.
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` MR. SMITH: Thank you, Your Honor.
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`This is Christopher Smith for the Petitioner. So
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`I'll go through the discussion and I'll address
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`the specific issues as I go.
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` So the Petitioner is asking for the
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`opportunity to submit a reply to Patent Owner's
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`preliminary response and particularly to submit a
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`reply that would respond to argument raised in the
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`preliminary response as well as add additional
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`declaration evidence, further evidence that the
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`Stahl paper, Exhibit 1006 and 1016 -- excuse me --
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`1106 of the two IPRs at issue were printed
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`publications and presented at the proceeding or
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`included in the proceedings book at the
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`proceedings, the Bled 13th Annual Conference.
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` JUDGE ARPIN: Counselor, I'm going to
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`stop you there for a moment. You said you were
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`going to submit additional evidence, including a
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`declaration.
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` Is this a declaration that you are
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`creating now or is it the declaration that existed
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`and was not filed before? And the evidence that
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`you would be submitting, is that different from
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`the declaration?
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` And I ask the same question, is that
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`evidence that you have only recently discovered or
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`is that evidence that was available to you at the
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`time the petition was filed?
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` MR. SMITH: It was not evidence that
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`was available at the time of the petition. The
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`one that we have -- there's a couple of buckets.
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`We have a declaration currently signed as of
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`October 3rd by one of the co-authors of the Stahl
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`paper, Dr. Sascha Schmitt. And Dr. Sascha Schmitt
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`actually was the presenter at the conference in
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`June 19th to 21st, 2000.
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` And he also actually received the
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`proceeding book at the conference, which he
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`declared was disseminated in and out to attendees
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`at the conference. And so that the declaration --
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` JUDGE ARPIN: Counselor, I'm going to
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`stop you there again. Was Mr. Schmitt not
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`available at the time the petition was filed?
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` MR. SMITH: We had not at that time got
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`in contact with Dr. Schmitt. Whether he was
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`available at the time, I cannot speak to.
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` JUDGE ARPIN: This was not an issue
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`that was addressed at the time of the petition and
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`you do not know whether it was something that you
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`could have filed with the petition?
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` MR. SMITH: It was not addressed at the
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`time of the petition. It was addressed after the
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`petition in response to the issues raised in the
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`preliminary response by Patent Owner. We were
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`able to contact Dr. Schmitt at that time and
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`that's when we were able to receive a declaration
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`from him.
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` JUDGE ARPIN: Counselor, the
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`preliminary response was filed I believe
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`August 12. That was basically two months ago. We
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`weren't contacted by you until October 4th, I
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`believe it was. Why the delay?
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` MR. SMITH: Well, initially, these are
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`initial submissions in the original petition. We
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`felt and we still feel that there's sufficient
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`proof there based on some of the precedent that we
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`read in the PTAB for a finding that at least at
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`the institution stage we met our burden of
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`publication.
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` I don't want to belabor the issue, but
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`the article that we submitted we feel on its face
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`indicates that it was available as of June 19th
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`through 21st, 2000 at that conference. There's a
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`heading on the paper.
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` We also submitted in our expert
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`declaration of Dr. Greenspun, I think it's
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`footnote 9. There was a cite to a web page where
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`you could order the paper or the proceedings for
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`the conference. Actually, there's a date stamp
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`updated 9/21/2000, which we felt was additional
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`evidence.
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` We also submitted with the
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`declaration -- or, excuse me -- with the exhibit
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`in the original petition the program for the
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`proceedings that also includes a citation to the
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`paper and the authors that were --
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` JUDGE ARPIN: Counselor, again, I'm
`
`sorry to keep doing this, but if you believe that
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`the information that you presented in the petition
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`is sufficient, then why the request for the reply?
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` MR. SMITH: Well, the reason for the
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`request for the reply is subsequent to that, there
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`were issues raised by the Patent Owner and then in
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`a recent decision, specifically the decision that
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`issued against Petitioner in IPR 2016-01015, for
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`example.
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` At that point, with that additional
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`issue, we had already sought out the additional
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`evidence from Dr. Schmitt with the idea that if we
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`were instituted and there was an objection to the
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`evidence, we would submit that as a supplement.
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` However, in view of the fact that the
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`rejection of the IPR 2016-01015, we thought at
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`this point, because we have a declaration, the
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`Board may find it helpful pre-institution. That
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`was the purpose for the call.
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` And the request for the call happened
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`the day after we got the declaration signed by
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`Dr. Schmitt. He was in Germany. There was a lot
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`of back on forth. So there was some time in
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`getting the declaration together.
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` JUDGE ARPIN: That was time spent after
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`the preliminary response was filed and not before
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`the petition was filed; is that correct?
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` MR. SMITH: That is correct.
`
` JUDGE ARPIN: Is there anything else
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`you would like to add at this time, Petitioner?
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` MR. SMITH: I would like to address the
`
`issue I think you had asked. We're one month away
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`from the institution deadline, how to support
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`this. You know, what I would propose is we would
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`file a short reply brief that would be five pages
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`or so. There's not a lot to discuss here. It
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`would mostly be attaching the declaration, and
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`then the Patent Owner would have an opportunity to
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`have a sur-reply. Again, I would imagine it would
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`be fairly short. I think we can do this in a
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`pretty condensed schedule before the deadline in
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`November.
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` JUDGE ARPIN: Well, it does take us a
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`little bit of time to draft the DI too. And if
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`we're having additional submissions -- I mean,
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`five pages you're talking about and then how much
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`time are you suggesting that we give you to
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`prepare this and how much time are you suggesting
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`that we give Patent Owner to respond to something
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`that they haven't seen?
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` MR. SMITH: For us, I would propose one
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`week. Again, you know, we're talking about some
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`specific declaration that they're kind of on their
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`face. It's not just a lot of having to chase down
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`evidence. It's really to look at the declaration
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`on its face and I guess discuss whether that's
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`sufficient or not.
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` So I can't put words in the mouth of
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`the Patent Owner, but I would think a week would
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`be a sufficient time to respond.
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` JUDGE ARPIN: For the Patent Owner to
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`respond to you or for you to file the document?
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` MR. SMITH: I mean, I think we could
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`file it within a week and I submit the Patent
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`Owner could reply in a week.
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` JUDGE ARPIN: That gives us two weeks
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`to review this material in light of everything
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`that has been submitted thus far and to draft a DI
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`and make it in before the statutory, I repeat that
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`word, statutory deadline.
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` Is that what you were suggesting?
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` MR. SMITH: I was suggesting that, but,
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`you know, to ease the concern, we could actually
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`file it by Friday if that would be better for the
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`Board and better for the patent owner. We would
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`be able to do that.
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` JUDGE ARPIN: Is there anything else
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`you would like to add at this time, Petitioner?
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` MR. SMITH: I would like to make the
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`point this is an evidentiary issue that we're
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`proposing here to establish publication date. It
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`wouldn't effect the substantive analysis of the
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`paper. You know, we're merely trying to establish
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`the date. So hopefully that would not be too
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`burdensome.
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` JUDGE ARPIN: This information that
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`you're suggesting you would like to add, the
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`declaration, and I don't want you to go into the
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`substance too deeply here, but just tell me, is it
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`entirely consistent with everything that's in the
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`petition now?
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` MR. SMITH: Okay. I want to explain
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`that. So the declaration -- I'm not going to get
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`into specifics of the declaration. The
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`declaration attaches the paper that was in the
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`proceeding book. The Stahl article that is in
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`Exhibit 1006 is the identical substantive article
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`that was in that proceeding book that is attached
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`to this declaration.
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` To be fully complete, there is some
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`formatting differences between the versions. They
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`have no impact on the substance at all. They're
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`everything we cited to, from figures to the actual
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`text are the same, but there are formatting
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`differences on like the way a figure is written in
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`the fig instead of spelled out as figure,
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`something like that, but there's no substantive
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`difference whatsoever. So from a substance
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`standpoint, it wouldn't change anything, anything
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`that we relied on.
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` JUDGE ARPIN: Counselor, if you believe
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`that you've stated before that the petition as it
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`is written now and the accompanying evidence is
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`sufficient, and if this declaration is just
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`entirely consistent with what you've already
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`filed, I'm having a little bit of a hard time
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`finding out what the purpose of this reply is.
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` Can you clarify this, please?
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` MR. SMITH: Well, what I would clarify
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`here is that my understanding under the PTAB rules
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`is in a lot of ways -- a lot of circumstances in
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`the way this plays out is that there's an
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`institution based on kind of the look and feel of
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`the article.
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` And then there's a process after
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`institution where the Patent Owner could submit an
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`objection and then at that point, us, being the
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`Petitioner, would have the opportunity to
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`supplement the record with this declaration which
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`we think proves without a doubt that the article
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`was publicly disseminated at that conference.
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` However, in review of the recent
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`decision again in the IPR 1015, the two IPRs --
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`excuse me -- the IPR 2016-1015 we're concerned
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`that we won't ever have that opportunity and
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`that's why we're -- and so, yes, I do believe that
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`what we submitted previously should be sufficient
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`in view of a lot of the case law that we've seen.
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` However, because we have a declaration
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`now, which we would have submitted after
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`institution, we thought the Board may, in
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`rendering its decision, want this now. And that's
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`why we're here.
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` JUDGE ARPIN: Is there anything else
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`you would like to add at this time, Petitioner?
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` MR. SMITH: That we also believe that
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`that would also further clarify the publication on
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`the website that talks about the last update of
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`2000 as well as the date actually on the front of
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`the article.
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` No further from Petitioner at this
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`time.
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` JUDGE ARPIN: Patent Owner, would you
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`like to respond to what Petitioner has just said?
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` MR. STERNE: Yes, Your Honor. This is
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`Robert Sterne for the Patent Owner.
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` There's been no showing of good cause
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`here, Your Honor. The Board should deny this
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`request. It's clear that what's going on here is
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`that the Petitioner was using recent decisions in
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`companion IPR institution decisions as a road map
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`to try to figure out what to do here. There's no
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`new fact that they're talking about. There's
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`nothing that satisfies good cause.
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` The Magnum Oil case shows, as the
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`Federal Circuit has stated in their precedential
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`decision, that the burden of persuasion and the
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`burden of proof rests on the Petitioner here in
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`these proceedings. They did not meet it when they
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`filed their petition, it seems to be the case,
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`even though we can't get a straight answer on
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`that.
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` So now what we want to do, as I
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`understand it, is a month before your institution
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`decision deadline they are allowed to have a
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`second opportunity to submit declaratory evidence
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`which, of course, gives us no opportunity to deal
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`with this in an effective way.
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` As we all know, on April 1st of this
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`year, the POPR rules were changed to allow Patent
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`Owner to submit declaratory evidence. You know,
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`we didn't do that here because we didn't need to
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`because the showing was not sufficient clearly.
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` And now we're being told that all of
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`this new information has come to light that is
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`really not needed, but is needed, should be
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`allowed to be submitted. We have no opportunity,
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`as a practical matter, to deal with that and we
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`devoted our POPR to what was in the petition and
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`we submit that it would be totally improper, based
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`on other panel decisions, to allow this
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`authorization to occur to file this reply with
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`this declaration.
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` And, of course, it also raises an
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`interesting point as to if they had filed such a
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`declaration, you know, how does -- how would we be
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`able to effectively deal with that in terms of
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`dealing with that?
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` So our position, Your Honor, is that
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`too little too late and that the Board should deny
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`this request.
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` JUDGE ARPIN: Thank you, Patent Owner.
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` Petitioner, because you bear the burden
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`here, it's your request. I'm going to ask whether
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`you have anything you would like to say in
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`response to what Mr. Sterne just said.
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` MR. SMITH: Thank you, Your Honor.
`
`This is Christopher Smith for the Petitioner.
`
` I wish to add as far as an opportunity
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`for the Patent Owner to respond, they would get an
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`opportunity to respond to our proposal in a
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`sur-reply. And so I think that they could
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`respond.
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` Again, we're not talking about a huge
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`burden of facts. We're talking about a short
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`declaration that they can review and respond to as
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`they see fit. And, you know, it's our
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`understanding that the Board has some discretion
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`on whether to issue this reply or not.
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` And I do believe as far as showing
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`cause, this is new evidence that further supports
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`proposition that this Stahl article is prior art
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`and that, you know, we could, therefore, go to the
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`next step of reviewing it on the merits, which we
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`believe on the merits it's a very strong
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`reference.
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` So for the purpose of -- or the goal of
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`reaching the correct answer, ultimately, on the
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`validity of the patent, we believe that it would
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`be good to be able to at least submit the evidence
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`and have a chance to have the patent reviewed in
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`view of the article.
`
` That's all, Your Honor.
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` JUDGE ARPIN: Thank you, Petitioner.
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` Counsel, I'm going to ask you to bear
`
`with us for a few moments. I'm going to place you
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`on mute and I'm going to confer with my colleagues
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`and we hope to be back to you in a few minutes.
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`Please be patient. Thank you.
`
` (Discussion held off the record.)
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` JUDGE ARPIN: Counsel, the panel is
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`back on the line.
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` We have considered the arguments
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`presented by the Petitioner and the response to
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`those arguments presented by the Patent Owner and
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`we are going to deny Petitioner's request to file
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`the reply at this time. We do so for several
`
`reasons.
`
` First, that Petitioner has told us that
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`it believes that its petition as it is written is
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`sufficient. And the information that it's
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`proposing, as we understand, would either be a
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`supplement to the petition or just confirming
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`material that's already in the petition. And at
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`this time, we do not see where that shows cause
`
`for granting a reply.
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` Secondly, there is a serious timing
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`issue here. We have a statutory deadline, which
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`is one month away, and we are not persuaded at
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`this time that the time frame that Petitioner has
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`proposed would allow, certainly the panel, but
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`maybe even the Patent Owner, the opportunity to
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`review and respond to this unknown or unseen at
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`this time evidence that the Petitioner proposes to
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`submit.
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` We will consider the petition and the
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`Patent Owner's preliminary response as they have
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`been filed and we shall issue a timely decision on
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`institution based on the materials that are of
`
`record at this point.
`
` If we do institute, Petitioner, there
`
`may be an opportunity through the submission of
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`supplemental information or in response to an
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`objection by the Patent Owner to provide the
`
`information that you have gathered and placed in
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`the record, but that will not be done in a reply
`
`at this time.
`
` With that said, Petitioner, is there
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`anything else that you would like to say at this
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`time?
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` MR. SMITH: No, Your Honor.
`
` JUDGE ARPIN: Patent Owner, is there
`
`anything that you would like to add at this time?
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` MR. STERNE: No. We have nothing to
`
`add, Your Honor. Thank you.
`
` JUDGE ARPIN: All right. Well, I look
`
`forward to the filing of the transcript at your
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`earliest convenience. And with that, I believe
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`t h a t t h i s c a l l i s a d j o u r n e d . T h a n k y o u .
`
` M R . S M I T H : T h a n k y o u , Y o u r H o n o r .
`
` M R . S T E R N E : T h a n k y o u , Y o u r H o n o r .
`
` ( W h e r e u p o n , a t 1 : 3 0 p . m . , t h e a b o v e
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` p r o c e e d i n g s w e r e c o n c l u d e d . )
`
` * * * * *
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`1 0
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`1 1
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`1 2
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`1 3
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`1 4
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`1 5
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`1 8
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`1 9
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`2 0
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`2 1
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`2 2
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` CERTIFICATE OF COURT REPORTER
`
` I, Denise M. Brunet, the court reporter
`
`before whom the foregoing proceedings were taken,
`
`do hereby certify that the proceedings
`
`were taken by me stenographically and thereafter
`
`reduced to print by means of computer-assisted
`
`transcription by me; that said proceedings are a
`
`true record; that I am neither counsel for,
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`related to, nor employed by any of the parties to
`
`this litigation and have no interest, financial or
`
`otherwise, in the outcome of this matter.
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` <%Signature%>
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`13
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` ________________________
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` Court Reporter
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`

`
`[& - calls]
`
`&
`
`& 2:11
`
`1
`1000 2:5
`1006 9:10 17:7
`1015 18:21
`1016 9:10
`11 1:11
`1100 2:12
`1106 9:11
`12 11:15
`1250 1:20
`13th 9:14
`19th 10:13 12:5
`1:00 1:19
`1:30 26:4
`1st 21:1
`
`2
`2000 10:13 12:6
`19:15
`20005 1:21 2:13
`2016 1:11
`2016-01012 3:5
`2016-01013 3:5
`2016-01015 13:6
`13:14
`2016-1015 18:22
`202 2:13
`21st 10:13 12:6
`22nd 2:5
`248 2:6
`
`3
`350 1:20
`358-4400 2:6
`37 6:17
`371-2600 2:13
`3rd 10:10
`
`4
`42.5 6:17
`48075 2:6
`4th 11:16
`6
`600 2:12
`9
`
`9 12:10
`9/21/2000 12:13
`a
`able 7:12 11:10,11
`16:8 21:19 23:8
`accompanying
`18:1
`accurate 4:18
`actual 17:13
`add 9:8 14:6 16:10
`16:19 19:11 22:9
`25:17,19
`additional 9:8,17
`12:13 13:8,9
`14:21
`address 4:14 8:8
`8:12 9:2 14:7
`addressed 8:19
`11:3,6,7
`adjourned 26:1
`afternoon 3:2,14
`ago 11:15
`agreement 7:13
`allow 4:11 21:2,13
`24:17
`allowed 20:19
`21:9
`alternative 6:10
`analysis 16:14
`annual 9:14
`answer 20:15 23:6
`appeal 1:1,14
`
`apply 5:18,19
`april 21:1
`argument 9:7
`arguments 23:21
`24:1
`arpin 1:16 3:2,3
`3:12,19 4:6 5:1,10
`5:13 7:19 8:1 9:15
`10:18 11:2,13
`12:20 14:1,5,19
`15:15,20 16:9,18
`17:21 19:10,19
`22:2 23:12,19
`25:16,20
`art 22:22
`article 12:4 17:6,7
`18:12,18 19:16
`22:22 23:10
`asked 14:8
`asking 9:4
`assisted 27:6
`assume 4:19
`atlantic 1:20
`attached 17:8
`attaches 17:5
`attaching 14:13
`attendees 10:16
`august 11:15
`authorization
`21:14
`authors 10:10
`12:19
`available 6:12
`7:11 10:4,7,20
`11:1 12:5
`avenue 2:12
`b
`back 13:21 23:16
`23:20
`based 8:16 11:21
`18:11 21:12 25:3
`
`Page 1
`
`basic 7:13
`basically 11:15
`bear 22:3 23:13
`begins 4:10
`behalf 2:2,8
`belabor 12:3
`believe 11:14,17
`12:21 17:21 19:2
`19:12 22:20 23:3
`23:7 25:22
`believes 24:6
`better 16:6,7
`bezos 2:10 3:18
`bit 5:14 14:20 18:4
`blakenship 1:16
`3:4
`bled 9:14
`board 1:1,14 5:3
`5:16,20 6:2,4,6,10
`6:16,21 7:8,10
`13:16 16:7 19:7
`20:2 21:22 22:18
`book 9:13 10:15
`17:6,8
`brief 14:11
`briefing 7:10
`brooks 2:4
`brookskushman....
`2:7
`brunet 1:17 27:2
`buckets 10:8
`burden 12:1 20:11
`20:12 22:3,15
`burdensome 16:17
`c
`c 2:

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