UNITED STATES PATENT AND TRADEMARK OFFICE
`
`______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`______________
`
`
`
`JUNIPER NETWORKS INC.,
`RUCKUS WIRELESS, INC.,
`BROCADE COMMUNICATION SYSTEMS, INC.,
`and NETGEAR, INC.,
`
`Petitioners,
`
`v.
`
`CHRIMAR SYSTEMS, INC.,
`
`Patent Owner.
`
`
`
`Case IPR2016-013891
`
`U.S. Patent No. 8,155,012 B2
`
`
`
`
`
`
`
`PATENT OWNER’S RESPONSE TO PETITIONERS’ FIRST
`SET OF OBJECTIONS TO PATENT OWNER’S EVIDENCE
`PURSUANT TO 37 C.F.R. § 42.64
`
`
`
`
`1 Ruckus Wireless, Inc., Brocade Communication Systems, Inc. and Netgear, Inc.
`
`(“Ruckus et al.”) filed a petition in (now terminated) IPR2017-00790, and Ruckus
`
`et al. has been joined to the instant proceeding.
`
`
`
`______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`______________
`
`
`
`JUNIPER NETWORKS INC.,
`RUCKUS WIRELESS, INC.,
`BROCADE COMMUNICATION SYSTEMS, INC.,
`and NETGEAR, INC.,
`
`Petitioners,
`
`v.
`
`CHRIMAR SYSTEMS, INC.,
`
`Patent Owner.
`
`
`
`Case IPR2016-013891
`
`U.S. Patent No. 8,155,012 B2
`
`
`
`
`
`
`
`PATENT OWNER’S RESPONSE TO PETITIONERS’ FIRST
`SET OF OBJECTIONS TO PATENT OWNER’S EVIDENCE
`PURSUANT TO 37 C.F.R. § 42.64
`
`
`
`
`1 Ruckus Wireless, Inc., Brocade Communication Systems, Inc. and Netgear, Inc.
`
`(“Ruckus et al.”) filed a petition in (now terminated) IPR2017-00790, and Ruckus
`
`et al. has been joined to the instant proceeding.
`
`
`
`Case No.: IPR2016-01389
`Patent No.: 8,155,012
`
`Atty. Dkt. No.: CHRMC0108IPR1
`
`Updated List of Exhibits
`
`
`
`
`
`Date
`Oct. 22, 2014
`
`
`
`Identifier
`
`Jan. 8, 2015
`
`
`
`Jan. 16, 2015
`
`
`
`Mar. 28,
`2016
`
`
`
`Exhibit
`Description
`No.
`2017 Memorandum Opinion and order
`denying AMX’s motion for summary
`judgment of non-infringement of the
`’012 Patent, Dkt. No. 96, Chrimar
`Sys., Inc., et al. v. AMX, LLC, Civil
`Action No. 6:13-cv-881-JDL, Eastern
`District of Texas
`2018 Memorandum Opinion and order
`construing certain terms of the ’012
`Patent, Dkt. No. 105, Chrimar Sys.,
`Inc., et al. v. AMX, LLC, Civil Action
`No. 6:13-cv-881-JDL, Eastern District
`of Texas
`2019 Memorandum Opinion and order
`construing certain terms of the ’012
`Patent and denying AMX’s motion for
`summary judgment of indefiniteness
`regarding the “distinguishing” terms
`of the ’012 Patent, Dkt. No. 108,
`Chrimar Sys., Inc., et al. v. AMX,
`LLC, Civil Action No. 6:13-cv-881-
`JDL, Eastern District of Texas
`2020 Memorandum Opinion and order
`denying AMX’s motion for summary
`judgment of indefiniteness regarding
`certain claims of the ’012, ’107, and
`’760 Patents, Dkt. No. 122, Chrimar
`Sys., Inc., et al. v. AMX, LLC, Civil
`Action No. 6:15-cv-164-JDL, Eastern
`District of Texas
`
`i
`
`
`
`Atty. Dkt. No.: CHRMC0108IPR1
`
`Date
`Mar. 28,
`2016
`
`Identifier
`
`
`
`June 20, 2016
`
`
`
`July 28, 2014
`
`
`
`May 12, 2016
`
`
`
`July 29, 2016
`
`
`
`Sept. 27,
`2016
`
`
`
`Case No.: IPR2016-01389
`Patent No.: 8,155,012
`
`
`
`Exhibit
`Description
`No.
`2021 Memorandum Opinion and Order,
`Dkt. No. 123, filed in Chrimar
`Systems, Inc., et al. v. Alcatel-Lucent,
`et al., Civil Action No. 6:15-cv-163-
`JDL, Eastern District of Texas
`2030 Memorandum Opinion and Order,
`Dkt. No. 454, filed in Chrimar
`Systems, Inc., et al. v. ADTRAN, Inc.,
`et al.¸ Civil Action No. 6:15-cv-618-
`JRG-JDL, Eastern District of Texas
`2032 Defendants’ Combined Motion for
`Summary Judgment and Claim
`Construction (selected portions), Dkt.
`No. 73, filed in Chrimar Systems, Inc.,
`et al. v. AMX, LLC, Civil Action No.
`6:13-cv-881-JDL, Eastern District of
`Texas
`2033 Defendants’ Responsive Claim
`Construction Brief (selected portions),
`Dkt. No. 432, filed in Chrimar Sys.,
`Inc., et al. v. ADTRAN, Inc., et al.,
`Civil Action No. 6:15-cv-618-JRG-
`JDL, Eastern District of Texas
`2034 Memorandum Opinion and Order,
`Dkt. No. 223, filed in Chrimar Sys.,
`Inc., et al. v. Alcatel-Lucent, et al.,
`Civil Action No. 6:15-cv-163-JDL,
`Eastern District of Texas
`2035 Memorandum Opinion and order on
`ALE’s motion to construe certain
`claim terms of the ’012 and ’760
`Patents, Dkt. No. 318, filed in
`Chrimar Sys., Inc., et al. v. AMX,
`LLC, Civil Action No. 6:15-cv-164-
`JDL, Eastern District of Texas
`
`ii
`
`
`
`Atty. Dkt. No.: CHRMC0108IPR1
`
`Date
`June 15, 2010
`
`Nov. 22,
`2010
`
`
`
`11/5/1999
`
`Identifier
`
`
`
`
`
`Madisetti Decl.
`Crayford Dep.
`Anderson 1999
`slides
`
`3/7-8/2000
`
`5/24-25/2000
`
`
`
`
`
`5/24/2000
`
`Dove slides
`
`5/24/2000
`
`Anderson 2000
`slides
`
`7/11-12/2000
`
`
`
`Case No.: IPR2016-01389
`Patent No.: 8,155,012
`
`
`
`Exhibit
`Description
`No.
`2036 Response to Office Action (Reexam
`Control No. 90/009,513) (June 15,
`2010)
`2037 Notice of Intent to Issue Ex Parte
`Reexamination Certificate (Reexam
`Control No. 90/009,513) (Nov. 22,
`2010)
`2038 Declaration of Dr. Vijay Madisetti
`2039 Deposition transcript of Ian Crayford
`2040
`Slides titled “DTE Power via MDI:
`System Requirements,” presented on
`November 5, 1999 by Arlan Anderson
`of Nortel Networks
`IEEE Power via MDI Task Force
`Meeting Minutes from March 7-8,
`2000
`IEEE Power via MDI Task Force
`Meeting Minutes from May 24-25,
`2000
`Slides titled “DTE Power over MDI:
`Building Consensus,” presented on
`May 24, 2000 by Ralph Andersson of
`TDK Semiconductor, Daniel Dove of
`Hewlett Packard, and Robert Muir of
`Level One Communications
`Slides titled “Powering and Discovery
`Alternatives,” presented on May 24,
`2000 by Arlan Anderson of Nortel
`Networks
`IEEE Power via MDI Task Force
`Meeting Minutes from July 11-12,
`2000
`
`2041
`
`2042
`
`2043
`
`2044
`
`2045
`
`iii
`
`
`
`Atty. Dkt. No.: CHRMC0108IPR1
`
`Date
`
`
`
`Identifier
`Karam slides
`
`May 1993
`
`Krol RFC
`
`
`
`Aug. 19,
`2016
`
`Camp Decl.
`‘392 Patent
`
`
`
`
`
`
`
`
`
`the ‘142 patent
`
`
`
`
`Case No.: IPR2016-01389
`Patent No.: 8,155,012
`
`
`
`Exhibit
`No.
`2046
`
`2047
`
`Description
`Slides titled “Technical Feasibility of
`Sending Common Mode Power on the
`Signal Pairs,” presented on May 24,
`2000 by Roger Karam and Karl
`Nakamura of Cisco Systems
`E. Krol & E. Hoffman, Internet
`Engineering Task Force Network
`Working Group, Request for
`Comments: 1462, “FYI on “What is
`the Internet?’”
`2048 Declaration of Clyde Camp
`2049 U.S. Patent No. 5,995,392
`2050
`Juniper Networks, Inc.’s Patent Rule
`4-2 Disclosures (Preliminary claim
`constructions) (August 19, 2016)
`2051 Madisetti Curriculum Vitae
`2052 U.S. Pat. No. 7,061,142 B1
`2053
`Supplemental Declaration of Dr. Vijay
`Madisetti
`2054 Declaration of Steven Johnson
`
`
`iv
`
`
`
`Atty. Dkt. No.: CHRMC0108IPR1
`
`Case No.: IPR2016-01389
`Patent No.: 8,155,012
`
`
`
`
`
`Pursuant to 37 C.F.R. § 42.64(b)(2), Patent Owner, Chrimar Systems, Inc.
`
`(“Patent Owner” or “Chrimar”), submits the following response to Petitioners’ First
`
`Set of Objections to Patent Owner’s Evidence Pursuant to 37 C.F.R. § 42.64.
`
`Patent Owner’s Response to Objections is timely under 37 C.F.R.
`
`§ 42.64(b)(2) because it is being filed and served within ten (10) business days of
`
`the filing of Petitioners’ Objections on April 11, 2017.
`
`This response addresses
`
`the objections where Petitioners properly
`
`“identif[ied] the grounds for the objection with sufficient particularity to allow
`
`correction in the form of supplemental evidence.” 37 C.F.R. § 42.64(b)(1).
`
`I.
`
`Patent Owner’s Response to Petitioners’ Objections to Exhibit
`2038 (“Declaration of Vijay Madisetti”)
`
`Petitioners object to Exhibit 2038 (“Declaration of Vijay Madisetti”) and seek
`
`to preclude “any reference or reliance thereon.” Petitioners provide no basis for
`
`exclusion of the entire declaration. 37 C.F.R. § 42.64(b)(1) states that any “objection
`
`must identify the grounds for the objection with sufficient particularity to allow
`
`correction in the form of supplemental evidence.” Petitioners fail to meet this
`
`burden.
`
`Instead of complying with 37 C.F.R. § 42.64(b)(1), Petitioners provide only
`
`“examples” of objections to only paragraphs 45, 56, 93, 157 and 191 of the
`
`1
`
`
`
`Atty. Dkt. No.: CHRMC0108IPR1
`
`Case No.: IPR2016-01389
`Patent No.: 8,155,012
`
`
`
`Declaration of Vijay Madisetti. The listing of examples is insufficient to raise an
`
`objection seeking to preclude “any reference or reliance” on the entire Madisetti
`
`Declaration.
`
`The objections made by example are also inapt and are addressed below.
`
`Fed. R. Evid. 702 and 703: Petitioners make this objection “because
`
`underlying facts or data on which the opinions in these paragraphs are purportedly
`
`based are either not disclosed or insufficient.” The basis for these paragraphs are
`
`provided in the Declaration of Vijay Madisetti. The support for these paragraphs
`
`include the knowledge, expertise and training of Dr. Madisetti as well as the
`
`documents and other references cited, including for example, documents from the
`
`IEEE. There is no explanation of how the support is allegedly “insufficient,” and
`
`therefore, Petitioners’ objection fails to satisfy 37 C.F.R. § 42.64(b)(1).
`
`Fed. R. Evid. 602: Paragraphs 45, 56, 93, 157 and 191 of Ex 2038 have
`
`sufficient support in the Declaration of Dr. Madisetti. Petitioners state that this
`
`expert testimony is “inadmissible under F.R.E. 602 because there is no sufficient
`
`evidence that the declarant has personal knowledge of those matters.” First, personal
`
`knowledge is not required for expert testimony. Fed. R. Evid. 702. Second, Dr.
`
`Madisetti has personal knowledge of the matters stated in Paragraphs 45, 56, 93, 157
`
`and 191 based on his education, skill and expertise in the field as well as his analysis
`
`of the documents and other references cited in his Declaration.
`
`2
`
`
`
`Atty. Dkt. No.: CHRMC0108IPR1
`
`Case No.: IPR2016-01389
`Patent No.: 8,155,012
`
`
`
`Fed. R. Evid. 801, 802 and 805: As explained above, these paragraphs of Dr.
`
`Madisetti’s Declaration are based on his education, skill and expertise in the field as
`
`well as his analysis of the documents and other references cited in his Declaration,
`
`not “what others told him.” Regardless, it is proper for Dr. Madisetti to rely on
`
`hearsay as part of his expert opinion. Interwoven, Inc. v. Vertical Computer Sys., CV
`
`10-04645 RS, 2013 WL 3786633, at *7 (N.D. Cal. July 18, 2013) (“Experts are,
`
`however, permitted to rely on hearsay evidence in coming to their conclusions, so
`
`long as an expert in the field would reasonably rely on that information”).
`
`Fed. R. Evid. 401, 402, and 403: These paragraphs of Dr. Madisetti’s
`
`Declaration are relevant because they contradict Petitioners’ obviousness assertions.
`
`Petitioners have not stated any reasons why these paragraphs are irrelevant,
`
`inadmissible, or more prejudicial than probative of these matters.
`
`Notwithstanding the above, Chrimar is providing a Supplemental Declaration
`
`of Dr. Madisetti (Ex. 2053) pursuant to 37 C.F.R. § 42.64(b)(2).
`
`II.
`
`Patent Owner’s Response to Petitioners’ Objections to Exhibit
`2048 (“Declaration of Clyde Camp”)
`
`Fed. R. Evid. 602: Paragraphs 4-11 of Ex 2048 have sufficient support that
`
`the declarant, Clyde Camp, has personal knowledge of the matters stated in those
`
`paragraphs. In his declaration, Mr. Camp avers that he makes his declaration “on
`
`personal knowledge.” (Ex. 2048, ¶ 1.) In addition, in ¶ 2, Mr. Camp provides details
`
`3
`
`
`
`Atty. Dkt. No.: CHRMC0108IPR1
`
`Case No.: IPR2016-01389
`Patent No.: 8,155,012
`
`
`
`of his background and involvement with the IEEE that support his knowledge of the
`
`facts stated in his declaration. In ¶ 3, Mr. Camp avers: “I was personally aware that
`
`this work [in the 802.3af Committee] was being done and I am familiar with the
`
`record-keeping system and policies used by IEEE 802 LAN/MAN Standards
`
`Committee including 802.3af.”
`
`Fed. R. Evid. 801, 802, and 805: Petitioners speculate that “Mr. Camp’s
`
`knowledge is based on what others told him” as the sole basis for their hearsay
`
`objections. Petitioners’ speculation lacks evidentiary support and is contrary to the
`
`record.
`
`Fed. R. Evid. 401, 402, and 403: The Camp declaration is relevant because it
`
`evidences that the IEEE exhibits referenced in it are authentic and are business
`
`records. Petitioners have not stated any reasons why the declaration is irrelevant,
`
`inadmissible, or more prejudicial than probative of these matters.
`
`III. Patent Owner’s Response to Petitioners’ Objections to Exhibits
`2040-2046
`
`Petitioners object to Exs. 2040-2046 collectively, not individually, so this
`
`response likewise addresses the exhibits collectively.
`
`Fed. R. Evid. 901: The exhibits are authenticated by the Camp Declaration,
`
`Ex. 2048. Fed. R. Evid. 901(a). Moreover, the documents themselves, and the links
`
`to them on the IEEE 802.3af website are further “evidence sufficient to support a
`
`4
`
`
`
`Atty. Dkt. No.: CHRMC0108IPR1
`
`Case No.: IPR2016-01389
`Patent No.: 8,155,012
`
`
`
`finding that the item[s] [are] what [Chrimar] claims [they are].” Fed. R. Evid. 901.
`
`Chrimar provides further evidence of authenticity via the declaration of Steven
`
`Johnson (Ex. 2054), who establishes that the documents were indexed and captured
`
`by the Internet Archive at about the time they were created.
`
`F.R.E. 801, 802, and 805: Chrimar is not offering Exs. 2040-2046 for the truth
`
`of what they say, only as evidence that the documents exist and make certain
`
`statements, whether true or not. These exhibits confirm that experts in the art were
`
`skeptical, not because the documents and their statements are necessarily true, but
`
`because the statements were made.
`
`Fed. R. Evid. 401, 402, and 403: Exs. 2040-2046 are relevant because they
`
`evidence that experts in the art were skeptical about the technological feasibility of
`
`applying operating power to the data-carrying wire pairs. Petitioners have not stated
`
`any reasons why the exhibits are irrelevant, inadmissible, or more prejudicial than
`
`probative of these matters.
`
`IV. Patent Owner’s Response to Petitioners’ Objections to Exhibit
`2047 (E. Krol & E. Hoffman, Internet Engineering Task Force
`Network Working Group, Request for Comments: 1462, “FYI on
`“What Is the Internet?’”)
`
`Petitioners’ contention that Exhibit 2047 has not been authenticated is
`
`incorrect. Indeed, Dr. Madesetti identifies the webpage from which he collected
`
`5
`
`
`
`Atty. Dkt. No.: CHRMC0108IPR1
`
`Case No.: IPR2016-01389
`Patent No.: 8,155,012
`
`
`
`Exhibit 2047 in his declaration (Ex. 2038). Exhibit 2047 is a true and correct copy
`
`of the content from that cited website.
`
`Furthermore, contrary to Petitioners’ claims, Exhibit 2047 is not hearsay any
`
`more than a dictionary is hearsay for its definitions because Exhibit 2047 is not being
`
`offered for the truth of the matter asserted. To the contrary, Exhibit 2047 merely
`
`provides a definition of the term “protocol” from an authoritative technical source,
`
`the weight of which can be decided by the Board while construing the term
`
`“protocol.” Finally, Exhibit 2047 is relevant because it provides additional context
`
`of what the term “protocol” means in the context of the computer networking field
`
`and the ‘107 Patent.
`
`V.
`
`Patent Owner’s Response to Objections to Exhibit 2049 (“U.S.
`Patent No. 5,995,392”)
`
`Contrary to Petitioners’ contention, Exhibit 2049 (U.S. Patent No. 5,995,392)
`
`is not hearsay because a U.S. patent is a qualifying public record under the hearsay
`
`exception of Federal Rules of Evidence 803(8). See Standard Haven Prod. Inc. v.
`
`Gencor Indus. Inc., 953 F.2d 1360, 1372-73 (Fed. Cir. 1991); Hay and Forage Indus.
`
`V. New Holland N.A., Inc., 25 F. Supp.2d 1170, 1180 (D. Kansas 1998) (stating that
`
`patents are “subject to the public records exception to the hearsay rule. See Fed. R.
`
`Evid. 803(8)(B)”). Even if the ‘392 Patent (Ex. 2049) was hearsay, it would be
`
`proper for Dr. Madisetti to rely on the ‘392 Patent as part of his expert opinion.
`
`6
`
`
`
`Atty. Dkt. No.: CHRMC0108IPR1
`
`Case No.: IPR2016-01389
`Patent No.: 8,155,012
`
`
`
`Interwoven, CV 10-04645 RS, 2013 WL 3786633, at *7 (N.D. Cal. July 18, 2013)
`
`(“Experts are, however, permitted to rely on hearsay evidence in coming to their
`
`conclusions, so long as an expert in the field would reasonably rely on that
`
`information”).
`
`Petitioners’ objection that Exhibit 2049 is not relevant is unfounded. At a
`
`minimum the ‘392 Patent indicates that during the relevant timeframe of the ‘107
`
`Patent, inventors in the relevant field were writing – and filing patents – about
`
`thermistors that could protect circuits without interfering with normal device power-
`
`up. This is relevant because it contradicts Petitioners’ reason to combine Hunter and
`
`Bulan, i.e., that the thermistors described in Hunter are inferior to the Bulan current
`
`limiting circuit. Patent Owner submits to the Board that Exhibit 2049 is relevant
`
`because it shows there was no reason to combine the Hunter and Bulan references.
`
`Finally, contrary to Petitioners’ objections, Patent Owner believes that the Board is
`
`fully capable of weighing the relevance of Exhibit 2049 without the concern of unfair
`
`prejudice or confusion of the issues.
`
`VI. Conclusion
`
`For the foregoing reasons, Patent Owner respectfully submits the above
`
`Response to Objections.
`
`
`Dated: April 25, 2017
`
`
`
`
`
` /Frank A. Angileri/
`
`
`
`
`
`Respectfully submitted,
`
`7
`
`
`
`Case No.: IPR2016-01389
`Patent No.: 8,155,012
`
`Atty. Dkt. No.: CHRMC0108IPR1
`
`Frank A. Angileri (Reg. No. 36,733)
`Thomas A. Lewry (Reg. No. 30,770)
`Marc Lorelli (Reg. No. 43,759)
`Christopher C. Smith (Reg. No. 59,669)
`Brooks Kushman P.C.
`1000 Town Center, 22nd Floor
`Southfield, MI 48075
`(248) 358-4400
`
`Richard W. Hoffmann (Reg. No. 33,711)
`Reising Ethington PC
`755 West Big Beaver Rd., Suite 1850
`Troy, Michigan 48084
`248.786.0163
`
`Attorneys for Patent Owner
`
`
`
`
`
`
`
`8
`
`
`
`Atty. Dkt. No.: CHRMC0108IPR1
`
`Case No.: IPR2016-01389
`Patent No.: 8,155,012
`
`
`
`Certificate of Service
`
`On April 25, 2017, a copy of this PATENT OWNER’S RESPONSE TO
`PETITIONERS’ FIRST SET OF OBJECTIONS TO PATENT OWNER’S
`EVIDENCE PURSUANT TO 37 C.F.R. § 42.640, along with Exhibits 2052-
`2054, has been served on Petitioners’ counsel via electronic mail at the email
`addresses shown below:
`
`
`Lead Counsel & Back-up Counsel for Juniper
`Jonathan Kagan, pro hac vice pending
`Nima Hefazi Reg. No. 63,658
`nhefazi@irell.com
`jkagan@irell.com
`Postal and Hand-Delivery Address:
`Postal and Hand-Delivery Address:
`IRELL & MANELLA, LLP
`IRELL & MANELLA, LLP
`840 Newport Center Drive, Suite 400
`1800 Avenue of the Stars, Suite 900
`Newport Beach, CA 92660
`Los Angeles, CA 90067
`Juniper-ChrimarIPR@irell.com
`Juniper-ChrimarIPR@irell.com
`
`Lead Counsel & Back up Counsel for Ruckus Wireless, Inc.,
`Brocade Communication Systems, Inc., & Netgear, Inc.
`Joseph Powers (Reg. No. 47,006)
`Christopher Tyson (Reg. No. 63,850)
`Duane Morris LLP
`Duane Morris LLP
`30 South 17th Street
`505 9th St. NW, Ste 1000
`Philadelphia PA 19103-4196
`Washington DC 20004
`JAPowers@duanemorris.com
`CJTyson@duanemorris.com
`
`
`Matthew S. Yungwirth
`DUANE MORRIS LLP
`1075 Peachtree Street, NE
`Suite 2000
`Atlanta, Georgia 30309
`msyungwirth@duanemorris.com
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
` /Frank A. Angileri/
`Frank A. Angileri (Reg. No. 36,733)
`Thomas A. Lewry (Reg. No. 30,770)
`Marc Lorelli (Reg. No. 43,759)
`
`9
`
`
`
`Atty. Dkt. No.: CHRMC0108IPR1
`
`Case No.: IPR2016-01389
`Patent No.: 8,155,012
`
`
`
`Christopher C. Smith (Reg. No. 59,669)
`Brooks Kushman P.C.
`1000 Town Center, 22nd Floor
`Southfield, MI 48075
`(248) 358-4400
`
`Richard W. Hoffmann (Reg. No. 33,711)
`Reising Ethington PC
`755 West Big Beaver Rd., Suite 1850
`Troy, Michigan 48084
`248.786.0163
`
`Attorneys for Patent Owner
`
`10
`
`
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