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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`———————
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`———————
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`UNIFIED PATENTS INC.
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`Petitioner
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`- vs. -
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`FALL LINE PATENTS, LLC
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`Patent Owner
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`———————
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`IPR2018-00043
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`U.S. Patent 9,454,748
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`PETITIONER’S RPI REPLY
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`Petitioner’s Reply to Patent Owner’s RPI Arguments
`IPR2018-00043 (U.S. Patent 9,454,748)
`TABLE OF CONTENTS
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`I.
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`Introduction ..................................................................................................... 1
`A. Other Board Panels Have Found Identical Arguments
`Unpersuasive. ....................................................................................... 2
`Unified’s Certification is Correct. ........................................................ 3
`B.
`II. Conclusion ..................................................................................................... 10
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`-ii-
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`I.
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`Introduction
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`Petitioner’s Reply to Patent Owner’s RPI Arguments
`IPR2018-00043 (U.S. Patent 9,454,748)
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`In accordance with the Order entered December 21, 2018 (Paper 19),
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`Petitioner Unified Patents Inc. (“Unified”) submits this Reply, responsive to Patent
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`Owner Fall Line Patents, LLC’s (“Fall Line”) arguments presented in its Preliminary
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`Response (“POPR,” Paper 5) and accompanying Exhibits, at the oral hearing, and in
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`its Motion filed January 11, 2019 (Paper 20, “Motion”) requesting that the Board
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`address its belatedly-presented arguments.
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`Unified correctly certified itself in the Petition as the sole real party-in-interest
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`(“RPI”), and Unified’s certification remains correct under the law as since clarified.
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`No other entity exercised control or could have exercised control over the filing of
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`the Petition or Unified’s conduct or participation in this proceeding. Fall Line’s
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`generalized, speculative allegations about Unified’s business model are similar to
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`previously rejected arguments, were already rejected at institution, and regardless
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`are insufficient to demonstrate Unified’s certification was incorrect.
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`The Board previously found that Fall Line’s POPR failed to provide
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`“sufficient evidence to reasonably bring into question the accuracy of Petitioner’s
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`[RPI] identification.” Institution Decision at 11. Fall Line, citing no new evidence,
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`argued for the first time during trial at the oral hearing (and argues now) that the
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`Board’s reasoning was based on the then-applicable “rebuttable presumption,” and
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`that the law has since changed. See, e.g., Motion at 3–5, Oral Hearing Transcript
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`(Paper 20) at 20:26–21:5. But nothing compels a change to the Board’s conclusion,
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`-1-
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`Petitioner’s Reply to Patent Owner’s RPI Arguments
`IPR2018-00043 (U.S. Patent 9,454,748)
`which was consistent with intervening decisions. In contrast to Federal Circuit
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`precedent, Fall Line has failed to produce evidence sufficient to place Unified’s RPI
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`certification in dispute. The Board should confirm in the final written decision that
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`Unified is the sole RPI in this proceeding.
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`A. Other Board Panels Have Found Identical Arguments
`Unpersuasive.
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`Other Board panels have already decided this issue under the most recent RPI
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`case law (as identified by Fall Line, Applications in Internet Time, LLC v. RPX
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`Corp., 897 F.3d 1336 (Fed. Cir. 2018) (“AIT”) and Worlds Inc. v. Bungie, Inc., 903
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`F.3d 1237 (Fed. Cir. 2018) (“Worlds”)) in its recently issued final written decision
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`in IPR2017-01430. Unified Patents Inc. v. Plectrum LLC, IPR2017-01430, Paper
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`30 at 9–14 (PTAB Nov. 13, 2018) (“Plectrum”). There, patent owner Plectrum
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`argued in its patent owner response that Unified was not the sole RPI. Plectrum’s
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`arguments were nearly identical to the arguments made in Fall Line’s POPR here,
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`which is unsurprising––Plectrum’s counsel also represents Fall Line in this
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`proceeding. Nearly identical evidence (Exhibits 2002–2005, with identical
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`numbering) was presented in Plectrum as well.
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`The Board’s final written decision in Plectrum considered the evidence and
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`arguments in light of AIT and Worlds. Plectrum at 9–14. In finding that Unified
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`was
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`the sole RPI,
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`the Board explained: “Patent Owner provides no
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`evidence…identifying any member entity that it alleges is controlling this particular
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`-2-
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`Petitioner’s Reply to Patent Owner’s RPI Arguments
`IPR2018-00043 (U.S. Patent 9,454,748)
`proceeding, or a member that has financed, in whole or in part, this proceeding.” Id.
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`at 12. Thus, even under AIT, “the evidence [was] insufficient to support that
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`Petitioner [had] requested [IPR2017-01430] on behalf of any particular member…or
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`to support that any of Petitioner’s members have had control over when and how
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`Petitioner spent
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`the revenue received from
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`its members related
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`to
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`this
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`proceeding....In sum, there is insufficient evidence that any specific member derives
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`benefit from this proceeding.” Id. at 13. The Board found that patent owner
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`Plectrum had only provided “mere assertions that unnamed real parties-in-interest
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`might exist.” Id. at 14 (emphasis in original). The Board also explained that it had
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`“no evidence tying Petitioner’s NPE-deterrent activities to any particular member
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`interested in the outcome of this proceeding….[W]e have insufficient information
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`regarding whether Petitioner evaluated any of its member’s interest when
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`determining whether to file IPR petitions.” Id (emphasis in original).
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`The Board’s reasoning in Plectrum applies equally here. Fall Line relies on
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`the same evidence that the Board has already considered, and like Plectrum in the
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`earlier proceeding, Fall Line has not identified or alleged any particular party should
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`have been named an RPI. Rather, it vaguely suggests all of Unified’s members are
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`RPIs. As the Board has previously found, and as it should find again, such
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`allegations, without evidence and without pointing to any particular relationship, are
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`insufficient to find that Unified’s certification is incorrect.
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`B. Unified’s Certification is Correct.
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`Petitioner’s Reply to Patent Owner’s RPI Arguments
`IPR2018-00043 (U.S. Patent 9,454,748)
`There is no reason for the Board to deviate from the analysis in Plectrum, or
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`its other previous Board decisions.1 Fall Line notes that the Federal Circuit in
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`Worlds disagreed with the use of a “rebuttal presumption” to shift the parties’ burden
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`of production on RPI identification. Motion at 4. But Fall Line omits what the
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`Federal Circuit subsequently specified was necessary to put the issue in dispute: “a
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`patent owner must produce some evidence to support its argument that a particular
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`third party should be named a real party in interest.” Worlds, 903 F.3d at 1244
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`(Fed. Cir. 2018) (bold emphasis added). Fall Line failed to produce such evidence.
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`During oral argument, the Board correctly recognized the flaws in Fall Line’s
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`argument. For example, Fall Line acknowledged that Worlds compelled a showing
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`that “particular third parties, not just potential third parties somewhere in the world”
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`were potential RPIs. Paper 20 at 46:11–22. But Judge Kenny noted that Fall Line
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`had not “identified…any specific member of Unified Patents that [Fall Line was]
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`contending is a real party-in-interest, or had any particular, specific interactions with
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`Unified Patents that would make it a real party-in-interest.” Id. at 50:21–24. Indeed,
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`1 Plectrum did not appeal the final written decision, which is now final. Further,
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`following AIT and Worlds, the Board has issued several additional decisions finding
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`that Unified is the sole RPI: IPR2018-00883, Paper 36 (PTAB Oct. 11, 2018)
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`(“Realtime”); IPR2018-01186, Paper 27 (PTAB Jan. 8, 2019); IPR2018-00952,
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`Paper 31 (PTAB Dec. 20, 2018).
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`Petitioner’s Reply to Patent Owner’s RPI Arguments
`IPR2018-00043 (U.S. Patent 9,454,748)
`Fall Line broadly alleged during oral argument only that Unified’s “members” are
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`RPIs. Id. at 46:23–47:2. And Fall Line’s counsel conceded it had not alleged any
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`particular member or party was an unnamed RPI, stating it had “not identified,
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`certainly not in this proceeding, in this record, any particular individual company
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`that has done that, that has had those interactions….an individual company hasn’t
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`been identified here….” Id. at 50:25–51:20. Counsel could only identify as the
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`alleged unnamed RPIs “Unified’s members” and at best “possibly a subset of those
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`members.” Id. at 51:21–25. Fall Line’s Motion is similarly vague where it asserts
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`“Petitioner’s clients are also real parties in interest.” Motion at 5.
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`No Unified member is an unnamed RPI in this proceeding. Understandably,
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`Fall Line could not identify any particular third party with which Unified had any
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`interactions that would make such a third party an unnamed RPI, because there are
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`none. Unified does not communicate with members as to litigation or IPR strategy
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`about any particular patent and did not communicate with any member as to
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`litigation or IPR strategy here. Jakel (EX1026), ¶¶ 9–11. Fall Line’s attempts to
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`shoehorn the instant case into the facts of AIT fail because the facts differ
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`substantially.
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`As Fall Line’s counsel acknowledged, even after Worlds’ reconsideration of
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`the presumption, “it makes sense even from practical standpoints that the Petitioner’s
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`initial representation of real party-in-interest will be accepted.” Paper 20 at 46:11–
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`14. If the patent owner brings forth sufficient evidence to call that practical
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`-5-
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`Petitioner’s Reply to Patent Owner’s RPI Arguments
`IPR2018-00043 (U.S. Patent 9,454,748)
`acceptance into question (i.e., “some evidence that tends to show that a particular
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`third party should be named,” Worlds, 903 F.3d at 1244), then the petitioner is
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`entitled to provide responsive evidence. For the reasons set forth above, Fall Line
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`has not put forth the requisite evidence to require Unified to present evidence in
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`rebuttal.
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`Nonetheless, to the extent the burden has shifted to Unified and given the
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`Board’s authorization to submit evidence, to erase all doubt, Unified herewith
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`submits the declaration of its CEO, Kevin Jakel (Jakel, Exhibit 1026), confirming
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`Unified is the sole RPI. Specifically, contrary to facts found pertinent in AIT, here:
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`1. There was no offer to, or request by, members of Unified to reach out to Fall Line
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`concerning its litigations. AIT, 897 F.3d at 1341–42; Jakel, ¶ 8.
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`2. Unified did not communicate with any member to ascertain their desires and
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`coordinate strategies, and it did not take last-minute efforts to avoid an express
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`statement of coordination. AIT, 897 F.3d at 1341–42; Jakel, ¶ 9. Indeed, the
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`record reflects that Unified never communicates with members regarding IPR or
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`litigation strategy and did not do so here. Jakel, ¶¶ 10-11.
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`3. Notwithstanding the fact that Fall Line has not identified any particular third
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`party, no Unified member had an earlier petition denied or was otherwise time-
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`barred from filing an IPR petition. AIT, 897 F.3d at 1353.
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`Petitioner’s Reply to Patent Owner’s RPI Arguments
`IPR2018-00043 (U.S. Patent 9,454,748)
`4. No Unified member made a “very significant payment shortly before” the
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`petition was filed and thus there is no implication that a payment was made for
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`this IPR. AIT, 897 F.3d at 1342; Jakel, ¶ 5.
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`5. Unified has no attorney-client relationship with its members and is not an
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`extension of any member’s in-house legal team. AIT, 897 F.3d at 1357, 1362;
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`Jakel, ¶ 4. Unified does not work to resolve members’ litigations. Jakel, ¶ 3.
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`6. There are no explicit or implicit agreements with its members that direct Unified
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`to file an IPR or perform any particular strategy. Id.
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`7. No outside party, including any member, made Unified aware of the ’748 Patent,
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`Fall Line, or Fall Line’s patent litigation. Jakel, ¶ 12.
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`8. Unified and its members do not share any individuals on their respective boards
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`of directors and have no corporate relationships with its members beyond its
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`membership agreements. AIT, 897 F.3d at 1354; Jakel, ¶ 7.
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`9. Unified works to clear technology “Zones.” That is, Unified has identified
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`specific Zones in which it works to challenge poor-quality patents. Jakel, ¶¶ 3,
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`6. Thus, Unified does not work on behalf of its members.
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`Fall Line’s counsel also addressed AIT during the oral hearing in contending
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`that, because Unified files IPRs as part of its NPE-deterrent activities, then its
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`members must be RPIs. Paper 20 at 49:15–19. But again, as the Board explained
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`in Plectrum, the “fact that members provide payment to Petitioner for a subscription
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`to Petitioner’s services alone is insufficient to show that specific members are
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`Petitioner’s Reply to Patent Owner’s RPI Arguments
`IPR2018-00043 (U.S. Patent 9,454,748)
`funding, directly or indirectly, this inter partes review.” Plectrum at 13. The Trial
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`Practice Guide (“TPG”) is clear that membership in an association, alone, does not
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`make an entity an RPI. 77 Fed. Reg. 48756, 48760 (Aug. 14, 2012) (“Party A does
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`not become a ‘real party-in-interest’ or a ‘privy’ of the Association simply based on
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`its membership in the Association.”). Fall Line’s attempt in its Motion (at 3–4) to
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`apply the facts in AIT to Unified fails because the Board’s prior analysis here
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`properly considered all facts previously presented, whereas the Federal Circuit in
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`AIT held that the Board failed to consider pertinent facts and remanded on that basis.
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`No such reconsideration is necessary here where the Board properly applied the TPG
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`factors.
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`Unified’s oft-stated interest is in “deter[ring] non-practicing entity (NPE)
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`patent litigation by protecting technology sectors that may be impacted by such NPE
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`assertions of poor-quality patents.” Jakel, ¶ 3. Unified performs this deterrence
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`regardless of whether “only non-members are involved in litigation” or whether
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`patents are unlitigated. Id. at ¶ 13. Unified’s interest is in protecting the industry as
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`a whole from NPE assertions based on low-quality patents, no matter who they are
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`asserted against. As Mr. Jakel’s testimony states: “There are no explicit or implicit
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`agreements with its members that direct or influence Unified to perform any
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`particular deterrent strategy, including filing this IPR.” Jakel, ¶ 3. Additionally,
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`“Unified is not an extension of any member’s in-house legal team.” Id. at ¶ 4.
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`Unified also “does not know their members’ litigation strategies” (nor even their
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`Petitioner’s Reply to Patent Owner’s RPI Arguments
`IPR2018-00043 (U.S. Patent 9,454,748)
`desires) because it “does not coordinate with its members” or “communicate[] . . .
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`regarding IPR or litigation strategy.” Id. at ¶¶ 9–11.
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`Fall Line’s demonstratives and its briefing appear to allege that AIT created
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`some sort of “benefit-plus-interest” standard for finding RPI. See Paper 18 at Slides
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`7, 14; Motion at 3. But the Board has rejected similar attempts to extend AIT’s
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`reasoning in the same context. For example, as the Board recently wrote in
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`instituting trial in another Unified case:
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`We agree with Petitioner that Patent Owner is overextending the reasoning of
`AIT. The RPI analysis set out in AIT and the common law require more than
`simply confining the analysis to determining whether a party benefits generally
`from the filing of this Petition and also has a relationship with the Petitioner.
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`Realtime at 14–15. Even if Unified’s members would benefit generally from this
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`IPR, those facts are insufficient to show any member is an RPI.
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`As with all its filings, “Unified did not file this IPR for the desire, payment,
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`or benefit of any particular member, or at the behest of any member.” Jakel, ¶ 8.
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`The evidence is clear: “Unified did not communicate with any member to ascertain
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`their desires,” because it “never communicates with any companies regarding IPR
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`or litigation strategy, and did not do so here.” Jakel, ¶ 9 (emphasis added).
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`Here, just as in Realtime, “there is no evidence that any of Petitioner's
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`members controlled, directed, or directly financed this proceeding.” Realtime at 16.
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`Further, “[t]here is no evidence that there was any communication at all between the
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`nonparties and Petitioner regarding filing this Petition…. there is no evidence here,
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`-9-
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`Petitioner’s Reply to Patent Owner’s RPI Arguments
`IPR2018-00043 (U.S. Patent 9,454,748)
`as there was in AIT, of communications between Petitioner and any of its members
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`regarding the underlying litigations involving the [’748] Patent.” Id. Similarly, “the
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`evidence does not point to any specific member whose ties with Petitioner are so
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`extensive to imply that Petitioner filed this IPR at the behest of that member or that
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`it was acting as an attorney-in-fact on behalf of that member.” Id. at 17–18.
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`Fall Line’s counsel also complained of a lack of factual evidence here; but it
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`raised and then abandoned the idea of seeking additional discovery. See Paper 8;
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`Paper 20 at 21:17–22:7. Any lack of factual evidence is of its own making. And
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`Fall Line’s counsel has previously reviewed Unified’s voluntary interrogatories in
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`IPR2017-01430 and IPR2016-00174 (submitted herewith as Exhibit 1027) and is
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`well aware of Unified’s independence and status as the sole RPI in all of its
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`proceedings. It complains that it could not “challenge the veracity of” Unified’s
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`discovery, but the Board has now granted Fall Line that ability. Paper 20 at 51:7–
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`13. Even considering Unified’s discovery, the same conclusion results: Unified is
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`the sole RPI.
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`II. Conclusion
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`Because Fall Line’s arguments and evidence do not establish that any party
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`aside from Unified is an RPI in this proceeding, the Board should confirm in its final
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`written decision that Unified’s certification was correct.
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`-10-
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`February 1, 2019
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`Petitioner’s Reply to Patent Owner’s RPI Arguments
`IPR2018-00043 (U.S. Patent 9,454,748)
`Respectfully submitted,
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`/David W. OBrien/
`David W. O’Brien
`Counsel for Petitioner
`Registration No. 40,107
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`-11-
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`Petitioner’s Reply to Patent Owner’s RPI Arguments
`IPR2018-00043 (U.S. Patent 9,454,748)
`PETITIONER’S EXHIBIT LIST
`February 1, 2019
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`EX1001
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`U.S. Patent 9,454,748 to J. David Payne
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`EX1002
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`Prosecution File History of U.S. Patent 9,454,748 (“’748 PH”)
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`EX1003
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`Prosecution File History of U.S. Patent 7,822,816 (“’816 PH”)
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`EX1004
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`U.S. Patent 7,822,816 to J. David Payne
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`EX1005
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`Declaration of A.L. Narasimha Reddy
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`EX1006
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`U.S. Patent 6,154,745 to Kari et al. (“Kari”)
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`EX1007
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`HTML 4 Unleashed by Darnell et al. (“Darnell”)
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`EX1008
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`Declaration of David Bader
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`EX1009
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`U.S. Patent 6,380,928 to Todd (“Todd”)
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`EX1010
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`U.S. Patent 6,381,603 to Chan et al. (“Chan”)
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`EX1011 Memorandum Opinion and Order, Macrosolve, Inc. v. Antenna
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`Software, Inc. et al., 6:11-cv-287 MHS-KNM (E.D. Tex. Jan. 21,
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`2014) (“’816 Markman Order”)
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`EX1012
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`Institution Decision, IPR2014-00140 (“’816 Institution”)
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`EX1013 Microsoft Computer Dictionary, 5th ed. (excerpt)
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`EX1014
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`U.S. Patent 6,222,483 to Twitchell et al. (“Twitchell”)
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`EX1015
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`U.S. Patent 5,043,736 to Darnell et al. (“Darnell ’736”)
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`EX1016
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`Dictionary of Computer Science (excerpt)
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`EX1017
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`Petitioner’s Reply to Patent Owner’s RPI Arguments
`IPR2018-00043 (U.S. Patent 9,454,748)
`Dictionary of Scientific and Technical Terms, 4th ed. (excerpt)
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`EX1018
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`Goran M. Djuknic & Robert E. Richton, Geolocation and Assisted
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`GPS, IEEE Computer, Vol. 34 no. 2, 123-125 (Feb. 2001)
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`EX1019
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`Robert S. Anthony, The Ultimate Personal Peripheral, PC Magazine,
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`Vol. 17 no. 5, 100-124 (Mar. 10, 1998)
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`EX1020
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`Johan Hjelm, Creating Location Services for the Wireless Web:
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`Professional Developer’s Guide (2002).
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`EX1021
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`Reply Declaration of A.L. Narasimha Reddy (“Reddy Reply Decl.”)
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`EX1022
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`Ira Kalb, Wireless
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`in Europe, May 2001,
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`available
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`at
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`https://web.archive.org/web/20011215142247/http://www-
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`106.ibm.com/developerworks/library/wi-eur/index.html, last retrieved
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`August 16, 2018 (“Kalb”).
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`EX1023
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`HTML 4.0 Guidelines for Mobile Access, W3C Note – 15 March 1999,
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`https://web.archive.org/web/20000823062148/
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`http://www.w3.org:80/TR/1999/NOTE-html40-mobile-19990315/,
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`last retrieved September 6, 2018 (“HTML 4.0 Note”).
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`EX1024
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`Timothy Berners-Lee, Hypertext Markup Language – 2.0, RFC 1866,
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`https://tools.ietf.org/pdf/rfc1866.pdf, last retrieved September 6, 2018
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`(“RFC 1866”).
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`EX1025
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`Reddy Declaration in IPR2014-00140.
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`Petitioner’s Reply to Patent Owner’s RPI Arguments
`IPR2018-00043 (U.S. Patent 9,454,748)
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`EX1026
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`Declaration of Kevin Jakel
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`EX1027
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`Unified Patents Voluntary Interrogatories
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`-14-
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
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`Unified Patents, Inc.
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`Petitioner
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`§
`§
`§
`§
`§
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`Petition for Inter Partes Review
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`IPR2018-00043
`U.S. Patent No. 9,454,748
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`
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`CERTIFICATE OF SERVICE
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`The undersigned certifies, in accordance with 37 C.F.R. § 42.6, that service
`was made on the Patent Owner as detailed below.
`Date of service February 1, 2019
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`Manner of service Electronic Service by E-Mail
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`Documents served Petitioner’s RPI Reply
`Exhibits 1026–1027
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`Persons served Terry L. Watt (terry.watt@crowedunlevy.com)
`Matthew J. Antonelli (matt@ahtlawfirm)
`Michael E. Ellis (michael@ahtlawfirm.com)
`Larry D. Thompson, Jr. (larry@ahtlawfirm.com)
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`/Raghav Bajaj/
`Raghav Bajaj
`Counsel for Petitioner
`Registration No. 66,630
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`-15-
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