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`Paper No. ___
`Filed: February 15, 2018
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`—————————————————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`—————————————————
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`CALIFORNIA INSTITUTE OF TECHNOLOGY,
`Patent Owner.
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`—————————————————
`
`Case IPR2017-00701
`Patent No. 7,421,032
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`—————————————————
`
`PATENT OWNER’S MOTION FOR SANCTIONS
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`
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`Case IPR2017-00701
`Patent 7,421,032
`I.
`INTRODUCTION AND STATEMENT OF PRECISE RELIEF REQUESTED
`
`
`
`Pursuant to 37 CFR §42.12 and the Order dated Feb 10, 2018 (Paper 41),
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`Patent Owner (“Caltech”) requests sanctions against Petitioner. The Order
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`followed a conference call on Feb 6, and additional communications. EX2036.
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`Cross-examination in an inter partes review proceeding is trial testimony
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`and strictly limited in scope, unlike expansive discovery depositions.
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`§42.53(d)(5)(ii). During cross-examination of Caltech’s witnesses, Dr.
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`Mitzenmacher and Dr. Divsalar, Petitioner repeatedly failed to stay within the
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`proper scope. Petitioner’s conduct violated numerous Board rules and orders, and
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`was an abuse of the discovery process. Indeed, Petitioner’s unauthorized
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`questioning amounts to “additional discovery” which Petitioner did not, and could
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`not, demonstrate was necessary “in the interests of justice.” §42.51(b)(2)(i).
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`II. LEGAL STANDARD
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`Under §42.12(a) & (b), the Board may “impose a sanction against a party for
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`misconduct.” Acts of misconduct include, inter alia, “failure to comply with an
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`applicable rule or order,” “abuse of discovery,” and “actions that harass” or cause
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`“unnecessary increase in the cost of the proceeding.” Id.; 35 U.S.C. §316(a)(6).
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`“[T]he scope of the examination is limited to the scope of the direct
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`testimony.” 37 CFR §42.53(d)(5)(ii); see also FRE 611(b) (“Cross-examination
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`should not go beyond the subject matter of the direct examination and matters
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`-1-
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`Case IPR2017-00701
`Patent 7,421,032
`affecting the witness’s credibility.”). In addition to a violation of Rule 53,
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`
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`“excessive questioning beyond the scope of a witness's direct testimony may be
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`considered an abuse of discovery.” IPR2013-00043, Paper 36 (July 16, 2013).
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`Moreover, discovery during inter partes review is strictly limited, and the
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`Board’s rules delineate between “routine discovery” and “additional discovery.” A
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`party seeking additional discovery must do so by motion, and must show that such
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`additional discovery is “necessary in the interest of justice.” 35 U.S.C. §316(a)(5);
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`see 37 CFR §42.51(b)(2)(i). Unauthorized additional discovery is a violation of
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`the Board’s rules and subject to sanctions. 37 CFR §42.12(a); see also Apple Inc.
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`v. Smartflash LLC, CMB2014-00102, Paper 20 at 2-4 (“The Board may impose an
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`appropriate sanction for abuse of discovery, including failure to adhere to the
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`Board’s rules governing taking testimony and the Testimony Guidelines. 37 C.F.R.
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`§ 42.12… Patent Owner now attempts to elicit information through deposition that
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`was denied to it as additional discovery.”).
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`III. ARGUMENT
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`As identified in Ex 2037 (and examples discussed below), an extraordinary
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`amount of Dr. Divsalar’s and Dr. Mitzenmacher’s cross-examination testimony
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`was beyond the scope of their respective declarations, and on many occasions,
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`beyond the scope of the six pending IPR proceedings between the parties.
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`-2-
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`Case IPR2017-00701
`Patent 7,421,032
`A. Dr. Divsalar
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`
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`Dr. Divsalar provided a short declaration addressing only a few discrete
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`points relating specifically to the Divsalar reference (EX2031). In particular, Dr.
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`Divsalar explained that the reference related to an “extremely simple” code
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`designed for the limited research purpose of mathematically assessing the “IGE
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`conjecture” relating to Berrou’s code. EX2031, ¶¶19, 23, 24, 29. Dr. Divsalar
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`explained that while the RA code was good for that limited exercise, the code still
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`performed “rather poor[ly]” compared to other correcting codes at the time. Id. at
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`¶ 32. Dr. Divsalar expressed his view that modifying an RA code to include
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`irregular repetition of information bits would not make sense on the basis that it
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`would add unnecessary difficulty and complexity at odds with the stated objective
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`in the paper, with no expectation of a corresponding benefit. Id. at ¶¶ 33-36. Dr.
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`Divsalar was also asked to address the hypothetical modification suggested by
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`Petitioner, which he explained was nonsensical and at odds with a key conclusion
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`in the Divsalar paper. Id. at ¶ 37. Dr. Divsalar did not address, nor was he asked
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`to address, any reference other than the Divsalar reference.
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`Despite the limited scope of Dr. Divsalar’s 16-page declaration (about 13
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`pages excluding qualifications, etc.), Petitioner’s district court counsel (appearing
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`pro hac vice) embarked upon a discovery campaign of generating over 280
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`transcript pages on a wide range of topics not addressed in Dr. Divsalar’s direct
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`-3-
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`Case IPR2017-00701
`Patent 7,421,032
`testimony. Tucker v. Peiler, 297 F. 570, 574-75 (2d Cir. 1924) (Comparing
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`
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`“…approximately 109 questions on direct examination and 700 questions on cross-
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`examination” to conclude “the cross-examination has been unduly prolonged.”).
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`The improper scope of questioning could not have been lost on Petitioner’s
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`counsel, as Dr. Divsalar reminded counsel over 100 times that questions were
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`being directed to subject matter not discussed in his declaration. See, e.g.,
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`EX1064, 141:28-12 (“I haven’t considered this exhibit in my declaration and I
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`have not prepared anything regarding this evidence here so since I’m not well
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`prepared to answer the specifics, I cannot really, you know, answer accurately your
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`questions.”); see also, e.g., 64:24-65:1; 78:9-11; 87:14-18; 95:13-17; 99:15-18;
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`115:4-7; 128:19-22; 134:2-5; 147:18-24; 156:12-17; 158:5-11; 159:2-14; 159:21-
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`160:3; 178:4-7; 184:24-185:2; 186:14-15; 188:11-12; 201:23-202:4; 243:7-9.
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`(Citations are to Ex 1064 of IPR2017-00210, which corresponds with Ex 1264 (-
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`219), Ex 2039 (-700, -701, -728)).
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`Nevertheless, counsel on multiple occasions expressed utter disregard for the
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`limited scope of Dr. Divsalar’s direct testimony. See, e.g., EX1064, 64:24-65:3
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`(“THE WITNESS: We haven’t talked about that, my declaration I didn’t mention
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`anything how to do, you know, [irregular] repetition in any way. Q. Whether it is in
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`your declaration or not, …”); 92:17-21 (“Q. So let me just give you the question.
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`We have Exhibit 1057. A. Which I haven’t discussed in my declaration. Q. I will
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`-4-
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`Case IPR2017-00701
`Patent 7,421,032
`grant you that. So for purposes of answering this question I take that as a given.”);
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`
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`see also, e.g., 81:14-16; 85:25-86:10; 90:2-8; 128:3-11.
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`The Allerton Conference: Dr. Divsalar provided no testimony regarding the
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`Allerton Conference other than stating the paper title and submission location.
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`Yet, Petitioner’s counsel questioned him about his attendance at the Allerton
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`Conferences and the Conference’s publication practices. See, e.g., EX1064, 30:24-
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`25 (“Is the Allerton Conference open to the public?”); 31:3-5 (“And when you
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`attend Allerton do you have to sign a nondisclosure agreement or any
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`confidentiality agreement of any kind?”); 36:3-6. Such questions were an
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`improper attempt to elicit fact discovery about the publication of the Frey
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`reference—an issue in dispute but unaddressed in Dr. Divsalar’s declaration.
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`Attorney-Created Tanner Graphs: Dr. Divsalar’s testimony on Tanner graphs
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`was that he and his co-authors at the time “did not consider Tanner graph
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`representation useful or applicable to concatenated convolutional codes.” EX2031,
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`¶ 26. Yet Petitioner chose to ask numerous questions about various Tanner graphs
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`newly generated by Petitioner’s lawyers, with no connection to Dr. Divsalar’s
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`direct testimony (see, e.g., EX1064, 78:4-5 (“Am I correct that this Exhibit 1057
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`shows the Tanner graph of an RA code where Q equals five?”); 106:11-14 (“It is
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`possible to do it and also Exhibit 1058 is one example. It is a demonstrative of an
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`irregular repeat-accumulate code, right?”)); 81:6-19 (“Q. Whether you considered
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`-5-
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`Case IPR2017-00701
`Patent 7,421,032
`[representing RA codes with Tanner graphs] or not…”)); 115:24-116:3 (“In
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`
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`making this change that’s shown in Ex. 1059…”)).
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`These questions were never used to assess Dr. Divsalar’s credentials or
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`credibility. They are transparent attempts to generate “additional discovery” and
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`new evidence for use in new arguments for Petitioner’s reply briefs. Indeed, these
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`figures and arguments are not in the petition materials, but are used to support new
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`argument in Petitioner’s Replies. See, e.g., IPR2017-00210 Reply at 12.
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`References not Addressed in Direct Testimony: Dr. Divsalar was clear that
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`his declaration only addressed his Divsalar reference and limited points of
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`consideration—not any other references. See, e.g., EX1064, 45:7-11 (“Q. So the
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`opinions you express in your declaration, they do not consider the Frey “Irregular
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`Turbocodes” paper? A. I haven’t mentioned prior art all in my declaration.”);
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`45:16-17 (“For preparation of my declaration I haven’t considered Luby at all.”);
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`141:18-23 (“I haven’t considered this exhibit [Luby] in my declaration and … I
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`cannot really, you know, answer accurately your questions.”); 198:4-7 (“I haven’t
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`read carefully [Frey] or prepared myself to answer this question. So I may – I can
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`make mistake and say something which is totally nonsense.”). Yet, Petitioner
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`proceeded to ask detailed questions, over several hours, regarding such references.
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`While Petitioner was entitled to ask which references were considered and
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`which were not, detailed questions about references expressly identified as not
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`-6-
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`Case IPR2017-00701
`Patent 7,421,032
`forming the basis of Dr. Divsalar’s opinion were inappropriate. See 1964 Ears,
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`
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`LLC v. Jerry Harvey Audio Holding, LLC, IPR2016-00494, Paper 56, p. 21 (July
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`19, 2017) (“[B]ecause Mr. Kadis’ opinion … was not based on the teachings of
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`Van Halteren ’223, Patent Owner’s questioning of Mr. Kadis regarding … Van
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`Halteren ’223 was beyond the proper scope of cross-examination.”).
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`Moreover, counsel attempted to leverage Dr. Divsalar’s lack of recent
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`review of the references to mischaracterize the content of those references. For
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`example, Mr. Dowd attempted to conflate Luby’s “message nodes” with
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`information bits. cf. EX1064, 147:20-24 Petitioner attempts to perpetuate this
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`confusion in its -219 Reply brief (e.g., pp. 1-3). But Luby never discusses
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`repetition of information bits. Dr. Mitzenmacher addressed this distinction at
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`length in his direct testimony. Mr. Dowd also mischaracterized Frey including,
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`inter alia, overstating realization of a coding gain in Frey. EX1064, 239:20-40.
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`But as explained by Dr. Mitzenmacher and stated in Frey, every profile Frey
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`actually tested was worse than Berrou’s regular turbo code. Id., p. 245, Figure 3.
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`Other examples include questions about the CCSDS standard, specific patent
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`claim limitations, Dr. Divsalar’s relationship with Dr. Frey, a 2005 paper by Dr.
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`Divsalar, and generator matrices. See Ex. 2037.
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`B. Dr. Mitzenmacher
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`In contrast to the limited testimony from Dr. Divsalar, Dr. Mitzenmacher
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`-7-
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`Case IPR2017-00701
`Patent 7,421,032
`appeared as Caltech’s primary expert witness, submitting four declarations
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`
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`addressing the petition materials. Dr. Mitzenmacher’s deposition also ventured
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`into various topics beyond the scope of the witness’ direct testimony. EX1062.1
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`Examples of improper questioning are provided below and in Exhibit 2037.
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`For example, like Dr. Divsalar, Dr. Mitzenmacher was subjected to
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`extensive questioning regarding Tanner graphs and figures newly created by
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`Petitioner’s lawyers, but absent from any petition materials or the witness’ direct
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`testimony. This included questions directed to Exhibits 1044 through 1049. See,
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`e.g., EX1062, 66:10-16 (“[T]his is a document we’ve made. You’ve now been
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`served a copy of it, but this is a document that neither you or the witness have seen
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`before and I’m going to ask questions about.”). Aside from the prejudice of Dr.
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`Mitzenmacher being ambushed by these exhibits, the exhibits appear to be an
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`attempt to present new patentability theories in Petitioner’s Reply briefs.
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`Moreover, several of the ’032 patent claims require encoding in accordance with a
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`Tanner graph. Caltech’s briefing has criticized the petition materials for failure to
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`provide sufficient Tanner graph analysis or explain why a POSA would describe
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`
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`1 Citations are to Ex 1062 in IPR2017-00210—see corresponding Ex 1262 (-
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`219), Ex. 1045 (-297), Ex. 2038 (-700, -701, -728).
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`-8-
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`Case IPR2017-00701
`Patent 7,421,032
`those prior art codes with Tanner graphs in the manner Caltech’s patents chose to
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`
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`illustrate codes. Petitioner’s new exhibits appeared to be directly geared only
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`toward improperly presenting new arguments not in its petitions.
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`Dr. Mitzenmacher was also questioned about topics that appear to be related
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`to the district court litigation, but not these IPRs. For example, Dr. Mitzenmacher
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`was asked about the 802.11n WiFi standard that Caltech has accused of
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`infringement in the district court litigation. See, e.g., EX1062, 445:11-12 (“Have
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`you ever looked at implementation of an 802.11n compliant encoder?”); 446:5-7.
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`Petitioner’s counsel also asked numerous questions about proposed
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`modifications to Divsalar absent from the petition materials. For example,
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`Petitioner’s Reply briefing now makes clear it has chosen to abandon its original
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`theory of modifying a q=3 RA code such that information bits are equally repeated
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`2 and 4 times. See, e.g., IPR2017-00210, Paper 35, pp.44-48 . Petitioner misused
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`the deposition of Dr. Mitzenmacher to fish for alternate theories. See, e.g.,
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`EX1062, 147:2-6 (“[S]o one bit was repeated Q+1 times, and all the other bits
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`were repeated Q times.”); 401:14-18 (“If Divsalar were modified so that some bits
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`were repeated three times and other bits were repeated four times…”).
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`C.
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`Petitioner’s Conduct Warrants Sanctions
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`During the February 6, 2018 conference call, the panel noted a typical
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`remedy is to give no weight to such improperly elicited testimony. Certainly such
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`-9-
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`Case IPR2017-00701
`Patent 7,421,032
`testimony in this case should be given no weight, but sanctions are additionally
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`
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`warranted in view of the extraordinary circumstances presented here. Without
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`sanctions, future parties will not be deterred from flouting the Board’s rules when
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`the only risk is not gaining an advantage. Accordingly, the Board should impose
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`one or more of the sanctions listed 37 CFR §42.12(b), and further identified below.
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`First, the cross-examination testimony of the witnesses should be struck
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`from the record. §42.12(b)(2). At a minimum, testimony elicited in violation of
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`§42.53(d)(5)(ii) should be struck from the record. Second, an order should issue
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`holding the direct testimony of both Dr. Mitzenmacher and Dr. Divsalar are
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`deemed facts established in the IPR proceedings. §42.12(b)(1). Third, an order
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`should provide for reasonable compensatory expenses, including attorney fees, for
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`costs reasonably related to excessive questioning and deposition time.
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`§42.12(b)(6). Moreover, a reprimand is warranted to highlight that pro hac vice
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`admission requires abiding by the Board’s rules and procedures.
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`IV. CONCLUSION
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`For the reasons above, Caltech’s request for sanctions should be granted.
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`Date: February 15, 2018
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`Respectfully submitted,
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`
`
`/ Michael T. Rosato /
`Michael T. Rosato, Lead Counsel
`Reg. No. 52,182
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`-10-
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`Case IPR2017-00701
`Patent 7,421,032
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`
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`EXHIBIT
`NO.
`
`LIST OF EXHIBITS
`
`DESCRIPTION
`
`2001
`
`2002
`
`2003
`
`2004
`
`2005
`
`2006
`
`2007
`
`2008
`
`2009
`
`2010
`
`Intentionally Left Blank
`
`Intentionally Left Blank
`
`Intentionally Left Blank
`
`Declaration of Dr. Michael Mitzenmacher
`
`Curriculum Vitae of Dr. Michael Mitzenmacher
`
`Kienle et al., “A synthesizable IP Core for DVB-S2 LDPC Code
`Decoding,” IEEE, 2005.
`
`Gomes et al., “Factorizable modulo M parallel architecture for
`DVB-S2 LDPC decoding,” Proceedings of the 6th Conference on
`Telecommunications, CONFTELE, 2007.
`
`Liva et al., “Design of LDPC Codes: A Survey and New Results,”
`Journal of Communications Software and Systems, 2(3):191-211,
`2006.
`
`Digital Video Broadcasting (DVB) User guidelines for the second
`generation systems for Broadcasting, Interactive Services, News
`Gathering and other broadband satellite applications (DVB-S2),
`ETSI TR 102 376, V11111 (2005-02).
`
`Kim et al., “Development of Rate-Compatible Structured LDPC
`CODEC Algorithms and Hardware IP,” Project Final Report,
`School of Electrical and Computer Engineering, Georgia Institute
`of Technology, December 2006.
`
`2011
`
`Richardson et al., “Efficient Encoding of Low-Density Parity-
`Check Codes,” March 6, 2001.
`
`-11-
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`Case IPR2017-00701
`Patent 7,421,032
`Lestable et al., “Irregular Repeat-Accumulate LDPC Code Proposal
`– Technology Overview,” IEEE 802.20 Working Group on Mobile
`Broadband Wireless Access, March 5, 2007.
`
`2012
`
`2013
`
`2014
`
`2015
`
`2016
`
`2017
`
`2018
`
`2019
`
`2020
`
`2021
`
`2022
`
`2023
`
`DVB-S2 Factsheet, DVB Project Office, August 2012.
`
`DVB-S2 Technology to Stimulate Demand for Broadband
`Interactive Services via Satellite, DVB Press Release, March 30,
`2004 (obtained from https://www.dvb.org/news/dvb-s2-technology-
`to-stimulate-demand-for-broadband-interact...).
`
`New SKY Perfect DVB-S2 satellite service for Japan, DVB-S2
`Press Release, October 13, 2008 (obtained from
`https://www.dvb.org/news/new-sky-perfect-dvb-s2-satellite-
`service-for-japan).
`
`BBC HDin DVB-S2 move, DVB-S to DVB-S2 Press Release, June
`2, 2011 (obtained from
`https://www.broadbandtvnews.com/2011/06,02,bbc-hd-in-dvb-s2-
`move/).
`
`Joint Stipulated Motion for Dismissal with Prejudice in California
`Institute of Technology vs. Hughes Communications, Inc. et al.,
`2:13-CV-7245 MRP-JEM (May 25, 2016).
`
`Amended Complaint for Patent Infringement Prejudice in
`California Institute of Technology vs. Hughes Communications,
`Inc. et al., 2:13-CV-7245 MRP-JEM (March 6, 2014).
`
`Lee, “LDPC Codes, Application to Next Generation
`Communication Systems,” Hughes Network Systems presentation,
`October 8, 2003.
`
`Declaration of Dr. Hui Jin
`
`March 7, 2000 Email from Dr. McEliece
`
`Dr. McEliece’s Lab Notebook
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`Jin, IRA.h code file, Head file for IRA, March 10, 2000, first
`version.
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`-12-
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`Case IPR2017-00701
`Patent 7,421,032
`Jin, IRA.cpp code file, Implementation file for class IRA, March
`10, 2000, first version.
`
`2024
`
`RA15_6 code file
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`Jin, IRAsimu.cpp code file, March 20, 2000, first version.
`
`makefile.bak code file
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`Jin, GenInter.cpp code file, April 12, 2000 modification.
`
`IRA48_8.prm code file
`
`Error floor, Wikipedia (obtained from
`https://en.wikipedia.org/wiki/Error_floor).
`
`Declaration of Dr. Dariush Divsalar
`
`Curriculum Vitae of Dr. Dariush Divsalar
`
`Transcript of Deposition of James A. Davis, September 5, 2017
`
`Intentionally Left Blank
`
`Intentionally Left Blank
`
`February 2, 2018 email and attachment from Michael T. Rosato to
`Trials.
`
`Summary of Out-of-Scope Questions from Dr. Miztenmacher and
`Dr. Divsalar’s Depositions
`
`Transcript of Deposition of Dr. Michael Mitzenmacher
`
`Transcript of Deposition of Dr. Dariush Divsalar
`
`2025
`
`2026
`
`2027
`
`2028
`
`2029
`
`2030
`
`2031
`
`2032
`
`2033
`
`2034
`
`2035
`
`2036
`
`2037
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`2038
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`2039
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`
`
`
`
`
`
`-13-
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`Case IPR2017-00701
`Patent 7,421,032
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`CERTIFICATE OF SERVICE
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`I certify that the foregoing Patent Owner’s Motion for Sanctions and
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`Exhibits 2036-2039 were served on this 15th day of February, 2018, on the
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`Petitioner at the electronic service addresses of the Petitioner as follows:
`
`Richard Goldenberg
`Dominic Massa
`Michael H. Smith
`James M. Dowd
`Mark D. Selwyn
`Arthur Shum
`WILMER CUTLER PICKERING HALE AND DORR LLP
`richard.goldenberg@wilmerhale.com
`dominic.massa@wilmerhale.com
`michaelh.smith@wilmerhale.com
`james.dowd@wilmerhale.com
`mark.selwyn@wilmerhale.com
`arthur.shum@wilmerhale.com
`
`
`
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`Date: February 15, 2018
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`
`
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`Respectfully submitted,
`
`
`/ Michael T. Rosato /
`Michael T. Rosato, Lead Counsel
`Reg. No. 52,182
`
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`-14-
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