throbber

`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______________
`
`CANON INC., CANON U.S.A, INC.; CANON FINANCIAL
`SERVICES, INC.; NIKON CORPORATION; NIKON, INC.;
`SAMSUNG ELECTRONICS CO., LTD.; SAMSUNG ELECTRONICS
`AMERICA, INC.; SANYO ELECTRIC CO., LTD.,
`Petitioners,
`
`v.
`
`PAPST LICENSING GMBH & CO., KG,
`Patent Owner.
`_______________
`
`Case IPR2018-00410
`Patent 6,895,449
`_______________
`
`
`PATENT OWNER PAPST LICENSING GMBH & CO., KG’S
`RESPONSE TO PETITIONER’S MOTION TO WAIVE OR SUSPEND
`RULE 37 C.F.R. § 42.122
`
`
`
`1
`
`
`
`
`
`
`
`
`
`
`
`
`
`

`

`INTRODUCTION
`I.
`Petitioner’s Motion to Waive or Suspend (“Petitioner’s Motion”) fails. IPR
`
`2017-00415 (the “’415 IPR”) was terminated on January 18, 2018. See ZTE (USA)
`
`Inc., v. Papst Licensing GmBH & Co. KG, Case IPR 2017-00415, Paper 32. Under
`
`PTAB precedent, a terminated IPR cannot be joined, and there is simply no
`
`procedural vehicle (by rule or statute) that would permit joinder of a terminated
`
`IPR.
`
`Even if the ’415 IPR was still active, Petitioner failed to meet its burden for
`
`untimely joinder by showing that that good cause exists or that the interests of
`
`justice favor joinder. Petitioner utterly fails to offer any excuse as to why it failed
`
`to timely join the ’415 IPR under 35 U.S.C. § 315(b)(1) or 37 CFR § 42.122(b).
`
`The reason is undoubtedly strategic—by not joining the IPR earlier, Petitioner
`
`circumvented the 35 U.S.C. 315(e) estoppel that attaches with a failed IPR. Only
`
`after Petitioner became aware that the final petitioner in the ’415 IPR had settled,
`
`did it seek to join the ’415 IPR. That Petitioner now regrets its deliberate choice
`
`not to join the ’415 IPR is no excuse. Good cause does not exist.
`
`Petitioner also failed to demonstrate that the interests of justice excuse its
`
`failure to abide by the PTAB’s rules for timely joining an IPR. Rather than ground
`
`its Motion in facts, Petitioner instead supports it argument regarding the interests
`
`of justice on the baseless allegation that Patent Owner’s settlement with Olympus
`
`
`
`2
`
`

`

`(and to a lesser extent ZTE and LG) is a “sweetheart deal.” Motion at 10. Despite
`
`Petitioner’s admission that it has not seen the Olympus settlement agreement and
`
`that it does not know the amount of the settlement, it recklessly condemns of the
`
`legitimacy of the Olympus settlement. See Motion at 5 (“Although Movants have
`
`not seen the settlement agreement between Papst and Olympus, Movants suspect
`
`that the settlement involves a small payment by Olympus …”). Patent Owner
`
`invites the Board to review the Olympus settlement to confirm that Petitioner’s
`
`assumption that it was a “sweetheart deal” is simply incorrect. See ’415 IPR, Paper
`
`No. 28, Ex. 2011 at 11 (showing the amount Olympus paid.) Moreover, when
`
`further considered in conjunction with the ZTE and LG settlements, Petitioner
`
`cannot credibly contend that these settlements were not legitimate. See ’415 IPR,
`
`Paper No. 24, Ex. 2010 (showing the amount LG paid); ’415 IPR, Paper No. 31,
`
`Ex. 2012 (showing the amount ZTE paid). Moreover, a “sweetheart deal” is not
`
`sufficient cause for Petitioner to belatedly join the ’415 IPR after its termination.
`
`Petitioner’s inaccurate and irrelevant attorney argument must be rejected.
`
`Petitioner’s otherwise bellicose commentary throughout its Motion about
`
`Papst (which Papst disputes) is immaterial to the issues before the Board.
`
`Petitioner indisputably and deliberately allowed the deadlines under 35 U.S.C. §
`
`315(b)(1) and 37 CFR § 42.122(b) to lapse. Petitioner’s disappointment with
`
`Olympus’s decision to settle the ’415 IPR does not establish that the interests of
`
`
`
`3
`
`

`

`justice require the Board to authorize Petitioner to revive a proceeding it
`
`intentionally chose to avoid (particularly here where Petitioner has not even
`
`requested to file a motion to revive), so that it can join the proceeding and pursue
`
`the action in Olympus’s place. See Apple Inc. v. Grobler, Case IPR 2014-00060,
`
`Paper 12 (PTAB Oct. 29, 2013).
`
`Petitioner’s Motion should be denied.
`
`II. RESPONSE TO STATEMENT OF RELEVANT FACTS
`Patent Owner has reviewed the Statement of Relevant Facts contained in
`
`Petitioner’s Motion to Waive or Suspend Rule 37 C.F.R § 42.122. Patent Owner’s
`
`response and denial of purported “facts” as set forth in Petitioner’s Statement of
`
`Relevant Facts is found at Exhibit 2002.
`
`III. LEGAL AUTHORITY AND ARGUMENT
`Rather than timely file an IPR on the ’449 patent, Petitioner instead let the
`
`one year deadline lapse. See 35 U.S.C. § 315(b) (“An inter partes review may not
`
`be instituted if the petition requesting the proceeding is filed more than 1 year after
`
`the date on which the petitioner, real party in interest, or privy of the petitioner is
`
`served with a complaint alleging infringement of the patent.”)
`
`Petitioner admits that it also let the deadline to join the ’415 IPR under 37
`
`C.F.R § 42.122 (which expired one month after institution) lapse. See IPR2018-
`
`00410, Paper 5 at 1 (“Petitioner acknowledges that the Instant Petition and Motion
`
`
`
`4
`
`

`

`for Joinder are being filed outside the one-month time period set forth in 37 C.F.R.
`
`§ 42.122(b).”) See also 37 CFR § 42.122(b) (“Any request for joinder must be filed
`
`[…] no later than one month after the institution date of any inter partes review for
`
`which joinder is requested.”) Now, with both deadlines long since passed,
`
`Petitioner seeks to join the already terminated ’415 IPR. Petitioner cites no
`
`authority to support its position that it should be permitted to join a terminated (and
`
`unrevived) IPR or that the PTAB has ever permitted a procedurally flawed joinder
`
`such as this.
`
`A. The ’415 IPR Has Been Terminated And Cannot Be Joined.
`Petitioner’s motion is premised on the factually incorrect argument that the
`
`’415 IPR is still pending. It is not. On January 18, 2018, three weeks after the
`
`Petitioner filed its Motion, the ’415 IPR was terminated. See ZTE (USA) Inc., v.
`
`Papst Licensing GmBH & Co. KG, Case IPR 2017-00415, Paper 32. The ’415 IPR
`
`cannot be joined—there is nothing to join. The commentary to the rules state:
`
`The AIA, however, does not provide for the ‘‘replacement’’ of a
`party. A petitioner may settle with the patent owner and upon entering
`the joint request, the review will terminate with respect to the
`petitioner. 35 U.S.C. 317, as amended, and 35 U.S.C. 327.
`Changes to Implement Inter Partes Review Proceedings, Post-Grant Review
`
`Proceedings, and Transitional Program for Covered Business Method Patents;
`
`Final Rule, 77 Fed. Reg. 48680, 48707 (Aug. 14, 2012).
`
`
`
`5
`
`

`

`Consistent with this commentary, the PTAB has repeatedly held that a
`
`terminated proceeding cannot be joined. In Apple Inc. v. Grobler, Case IPR2014-
`
`00060, Paper 12 (PTAB Oct. 29, 2013), the Board refused to grant an untimely
`
`joinder motion by which Apple sought to join a proceeding that was terminating
`
`via settlement:
`
`Apple’s disappointment with Sony’s decision to settle IPR2013-00076
`does not establish that the interests of justice require the Board to
`authorize Apple to file a motion to revive a proceeding it deliberately
`chose to avoid, so that Apple can join the revived proceeding and
`pursue the action in Sony’s stead.
`Id. at 5-6.
`
`Likewise, in Google Inc. v. PersonalWeb Techs., LLC, Case IPR2014-
`
`00977, Paper 10 (PTAB Oct. 30, 2014), the Board refused to grant an untimely
`
`joinder motion in which Google sought to join a proceeding that was terminating
`
`via settlement. The Board entered an order
`
`terminating
`
`the underlying
`
`proceeding, Rackspace US, Inc. v. PersonalWeb Techs., LLC, Case IPR2014-
`
`00059, shortly before denying Google’s joinder motion.
`
` In Roche Molecular Systems, Inc. v. Illumina, Inc., Case IPR2015-01091,
`
`Paper 18 (PTAB Oct. 30, 2015), the Board refused to grant an untimely joinder
`
`motion in which Roche sought to join a proceeding in which Ariosa was the lead
`
`petitioner. Roche purchased Ariosa during the pendency of the Ariosa IPR and
`
`wanted to join a petition with new prior art to Ariosa’s original petition. But Roche
`
`
`
`6
`
`

`

`knew of the Ariosa IPR when it bought Ariosa, and waited more than six months to
`
`file its own IPR after acquiring Ariosa, which was also more than three months
`
`after the Ariosa IPR was instituted. In refusing to grant joinder, the Board
`
`criticized Roche’s delay in light of Roche’s knowledge of the disputes between
`
`Ariosa and Illumina, the patent owner.
`
`PTAB precedent does not permit joinder of a terminated IPR. Petitioner’s
`
`attempt to waive or suspend Rule 37 C.F.R § 42.122 fails.
`
`B. Good Cause Does Not Exist.
`Petitioner offers no excuse for allowing the 37 C.F.R § 42.122 deadline to
`
`lapse by approximately six months before belatedly seeking joinder. Petitioner’s
`
`decision not to timely join the IPR was strategic. By not joining the ’415 IPR
`
`within the deadline, Petitioner sought to benefit from the outcome of the IPR
`
`without being bound by 35 U.S.C. 315 estoppel. Petitioner points out that Olympus
`
`filed a motion for joinder with the ’415 IPR on June 16, 2017, and that motion was
`
`granted. Motion at 5. But Petitioner fails to account for the fact that it could have
`
`done precisely what Olympus did—timely join the ’415 IPR within the deadline
`
`imposed by 37 C.F.R § 42.122. Nothing prevented Petitioner from complying with
`
`the Rules. In fact, on July 20, 2017, Petitioner Samsung demonstrated its
`
`knowledge and familiarity with the deadline imposed by 37 C.F.R § 42.122 by
`
`seeking to join a different IPR with Olympus relating to another Papst patent. See
`
`
`
`7
`
`

`

`IPR 2017-01808, Paper 4 at 5 (“The Olympus/Samsung Petition and concurrently
`
`filed Motion for Joinder are timely under 35 U.S.C. § 315(c) and 37 C.F.R. § 42.22
`
`and 4.122(b).”) Petitioner’s strategic decision not to join the ’415 IPR with
`
`Olympus cannot now be undone. Petitioner must now live with its decision. Good
`
`cause does not exist.
`
`C. The Interests of Justice Weigh Against Waiver or
`Suspension.
`The interests of justice weigh heavily against Petitioner’s request for waiver
`
`or suspension of 37 C.F.R § 42.122.
`
`1)
`
`Petitioner’s Unfounded Assumption that the Papst-
`Olympus Settlement Was a So-Called “Sweetheart
`Deal” Is Incorrect.
`Without any knowledge of the amount or terms of the Papst-Olympus
`
`settlement, Petitioner blindly hypothesizes that the settlement was a “‘sweetheart
`
`deal’ to induce Olympus to settle.” Motion at 10. Petitioner’s hypothesis is simply
`
`incorrect. Papst invites the Board to review the Papst-Olympus settlement to
`
`confirm its legitimacy. See ’415 IPR, Paper No. 28, Ex. 2011 at 11 (showing the
`
`amount Olympus paid.) Moreover, when further considered in conjunction with the
`
`settlements of ZTE and LG (the other former petitioners for the ’415 IPR),
`
`Petitioner’s argument fails. See ’415 IPR, Paper No. 24, Ex. 2010 (showing the
`
`amount LG paid); ’415 IPR, Paper No. 31, Ex. 2012 (showing the amount ZTE
`
`
`
`8
`
`

`

`paid.) Petitioner’s central argument is demonstrably untrue. Petitioner’s Motion
`
`fails.
`
`In addition to being factually inaccurate, Petitioner’s argument is also
`
`irrelevant. Petitioner’s baseless and inflammatory accusations of a “scheme” or
`
`“gamesmanship” are nothing more than attorney argument that must be rejected.
`
`Petitioner fails to cite any authority for its position that such facts would even be
`
`considered as relevant to the “interests of justice” inquiry. Rather, the case law
`
`teaches the opposite. See Apple Inc. v. Grobler, Case IPR2014-00060, Paper 12 at
`
`5-6.
`
`2)
`
`The Primary Case Cited By Petitioner Is Inapposite
`and Favors Denial of Petitioner’s Motion.
`In support of its Motion, Petitioner cites only Sony Corp. v. Network-1
`
`Security Solutions, IPR2013-00495, Paper 13 (PTAB Sept. 16, 2013). But Sony
`
`Corp. favors denial of Petitioner’s Motion. In Sony Corp., the PTAB granted the
`
`late-filed joinder but the facts were very different than those presented to this
`
`Board. The Sony Corp. panel looked at both the substantive and procedural issues
`
`associated with the request for late joinder. Substantively, the panel found that
`
`joinder “do[es] not raise any issues that are not already before the Board.” Id. at 5.
`
`Not so here. The terminated ’415 IPR is not “already before the Board” because it
`
`was terminated and no longer exists. Thus, joinder would require an entirely new
`
`set of issues to be determined by the Board.
`9
`
`
`
`

`

`Procedurally, the Sony Corp. panel found that the impact of joinder on the
`
`existing schedule would be minimal because “joinder would require no change to
`
`the existing schedule” and the movant would have a limited “understudy” role. Not
`
`so here. The impact and associated prejudice could not be greater. There is no
`
`active proceeding to join. As a result, the entire revived proceeding would impact
`
`the existing schedule because there is no existing schedule. Also, Petitioner would
`
`not simply be an “understudy” in the ’415 IPR; rather they would have the “lead”
`
`role as the petitioner.
`
`Also, the Sony Corp. panel evaluated other considerations that merited
`
`granting of late joinder not present here. For example, in Sony Corp. the panel
`
`observed that the petitioners tried multiple times to timely join other IPRs for the
`
`patent at issue, but were denied by the Board. “The fact that Petitioners attempted
`
`previously—within the one-month time period—to be joined to Case IPR2013-
`
`00071 weighs in favor of considering Petitioners’ request outside the one-month
`
`time period.” Id. at 7. Here, Petitioner made no prior attempt to initiate or join any
`
`IPR related to the ’449 patent.
`
`Finally, the Sony Corp. panel commented that the “replacement” of an
`
`existing party that already settled with Patent Owner—which is akin to the
`
`circumstance before this Board—is a far different. In Sony Corp., the panel found
`
`that petitioners were “not seeking to replace an existing petitioner that settled with
`
`
`
`10
`
`

`

`Patent Owner, whereby the review would terminate with respect to that petitioner
`
`only under 35 U.S.C. § 317, but rather to join the existing proceeding before such
`
`settlement occurs.” Here, the facts are much worse for Petitioner. Petitioner’s
`
`request is far more intrusive than “replacement,” as condemned by the Sony Corp.
`
`panel, because there is no party to even replace. Indeed, Petitioner’s requested
`
`relief would require a complete revival of the terminated proceeding. Petitioner’s
`
`Motion fails.
`
`3)
`
`All Grounds of Patentability Asserted in the Instant
`Petition are New.
`Petitioner incorrectly claims that the “Instant Petition does not assert any
`
`new grounds of patentability” because it “challenges the same claims of the ’449
`
`patent based on the same arguments, evidence and grounds of unpatentability.”
`
`Motion at 9. But Petitioner fails to recognize that the ’415 IPR was terminated and
`
`no longer exists and therefore the Instant Petition cannot be compared to it. The
`
`Instant Petition is therefore an entirely new and original work. Thus, the
`
`substantive basis for the Sony Corp. panel granting joinder is not present here.
`
`4)
`
`The Requested Waiver or Suspension Will Unduly
`and Unfairly Impact the Schedule Because the ’415
`IPR No Longer Is Active.
`Petitioner dismissively claims that the impact on the ’415 IPR schedule
`
`would result “little, if any, disruption”—not so. See Motion at 9. It is difficult to
`
`envision a scenario where already the terminated ’415 IPR would proceed without
`
`
`
`11
`
`

`

`undue delay and major adjustments to the scheduling order. When the ’415 IPR
`
`was terminated on January 18, 2018, so too was its schedule. The schedule
`
`Petitioner references no longer exists. Therefore, any joinder of the terminated
`
`’415 IPR proceeding will necessarily require adoption of a new, significantly
`
`delayed schedule when compared to the prior (terminated) schedule.
`
`Petitioner’s arguments also fail even if ’415 IPR had not been terminated
`
`and the defunct schedule was still in place. The two remaining deadlines—
`
`Petitioner’s Reply on January 5, 2018 and the hearing on February 13, 2018—will
`
`certainly be impacted if joinder (and revival) of the ’415 IPR is permitted. The
`
`January 5, 2018 deadline for Petitioner’s Reply has long since passed. Petitioner
`
`now asks the Board to allow a later “appropriate” deadline—an admission that the
`
`schedule will necessarily be impacted because any Reply brief filed by Petitioner
`
`will necessarily require departure from the original schedule for the ’415 IPR, and
`
`will prejudice Patent Owner.
`
`Moreover, the originally scheduled February 13th hearing date cannot
`
`realistically go forward. The ’415 IPR would first have to be revived—a motion
`
`Petitioner has not even requested permission to file. Then, a new schedule would
`
`have to be put in place, but that new schedule would cause a tremendous delay as
`
`compared to the terminated ’415 IPR’s prior schedule. It would be indisputably
`
`unfair and prejudicial to require Patent Owner to prepare for a hearing on February
`
`
`
`12
`
`

`

`13 (that was previously cancelled) with notice of only a few days for an IPR that
`
`was not actively worked for months because all parties actually participating in the
`
`IPR focused on finalizing settlement papers. Petitioner’s (revival and) joinder at
`
`this late stage will be nothing but disruptive and prejudicial to Patent Owner. This
`
`factor weighs heavily against suspension or waiver of Rule 42.122(b).
`
`IV. Public Policy and Legislative History Compel Denial of Joinder
`A. Waiver or Suspension of the Deadline Would Have a
`Chilling Effect on Settlement.
`Granting Petitioner’s Motion would set a precedent that discourage future
`
`settlements—particularly early settlements. Public policy favors allowing parties to
`
`settle pending IPRs. The United States Patent and Trademark Office’s Guide
`
`states:
`
`N. Settlement. There are strong public policy reasons to favor
`settlement between the parties to a proceeding. The Board will be
`available to facilitate settlement discussions, and where appropriate,
`may require a settlement discussion as part of the proceeding. The
`Board expects that a proceeding will terminate after the filing of a
`settlement agreement, unless the Board has already decided the merits
`of the proceeding. The Office Patent Trial Practice Guide, 77 Fed.
`Reg. 48756, 48768 (Aug. 14 2012).
`Consistent with this policy, the Board should not grant suspension or waiver
`
`of the Rule 37 C.F.R § 42.122. A contrary decision would mean far fewer
`
`settlements will occur in multi-defendant cases until at least one month after
`
`institution of an IPR (many months after institution if the original petitioner and
`
`patent owner must wait to see if another defendant is permitted to join after that
`13
`
`
`
`

`

`defendant files a motion to join) because the patent owner will always be
`
`concerned that even if it settles with the original petitioner, another defendant will
`
`seek to join or be permitted to join the terminated IPR thereby depriving the patent
`
`owner of much of the value of its settlement with the original petitioner. Here,
`
`Petitioner only has itself to blame for not timely filing an IPR pursuant to 37 C.F.R
`
`§ 42.122.
`
`B.
`
`Permitting Joinder of a Terminated IPR Would Encourage
`Strategic Non-Joinder Until After Termination
`to
`Circumvent Estoppel.
`Petitioner intentionally chose not to join the ’415 IPR within the statutorily
`
`mandated time period which enabled it to avoid 35 U.S.C. § 315(e) estoppel that
`
`attaches to failed IPRs in district court. Despite reaping the benefits of the ’415
`
`IPR but not being estopped by it, Petitioner cannot now agree to accept the
`
`estoppel associated with joinder of the IPR because it now realizes that is the only
`
`way to maintain the IPR. An order from the Board permitting tardy joinder after
`
`settlement will encourage future movants to avoid estoppel by not timely joining
`
`IPRs, and then belatedly joining IPRs only after the parties settle. Thus, these late-
`
`joining parties will avoid estoppel by waiting to see if the original petitioner
`
`settles. If the original petitioner does not settle, the party benefits from the original
`
`petitioner attempting to invalidate the patent without incurring any risk of estoppel.
`
`
`
`14
`
`

`

`And only if the original petitioner settles would the third party seek to join. This
`
`tactic, which was employed here by the Petitioner, cannot be allowed.
`
`V. Conclusion
`The Board should exercise its discretion to deny suspension or waiver.
`
`Petitioner fails to show good cause for its requested suspension or waiver of Rule
`
`42.122(b). In addition, the interests of justice strongly disfavor the requested
`
`suspension or waiver. Petitioner simply cannot join a terminated IPR. Public policy
`
`and scheduling considerations weigh against joinder. PTAB precedent and the
`
`legislative history of the joinder and settlement provisions further support that
`
`joinder should be denied under the present fact pattern, particularly when the
`
`Petitioner attempting to join has deliberately chosen not to file an IPR petition and
`
`seeks to join an IPR that has been terminated.
`
`
`Dated: 01/26/2018
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`/Gregory S. Donahue/
`
`Gregory S. Donahue
`Reg. No. 47,531
`DiNovo Price LLP
`7000 North MoPac Expressway
`Suite 350
`Austin, Texas 78731
`Lead Counsel for Patent Owner
`
`
`
`15
`
`

`

`CERTIFICATE OF SERVICE
`
`I hereby certify that on this 26th day of January 2018, a true and correct
`
`copy of the foregoing PATENT OWNER PAPST LICENSING GMBH & CO.,
`
`KG’S RESPONSE TO PETITIONER’S MOTION TO WAIVE OR SUSPEND
`
`UNDER 37 C.F.R. § 42.122 was served by electronic mail upon the following
`
`counsel of record for Petitioners:
`
`David M. Maiorana
`Matthew W. Johnson
`David L. Witcoff
`Marc S. Blackman
`JONES DAY
`dmaiorana@jonesday.com
`mwjohnson@jonesday.com
`dlwitcoff@jonesday.com
`msblackman@jonesday.com
`
`Mark Ungerman
`UNGERMAN IP PLLC
`mungerman@ungermanip.com
`
`
`
`
`
`
`
`
`
`
`
`Carrie A. Beyer
`Nikola Colic
`Brian C. Rupp
`DRINKER BIDDLE & REATH
`LLP
`carrie.beyer@dbr.com
`nick.colic@dbr.com
`brian.rupp@dbr.com
`
`
`
`
`/Gregory S. Donahue/
`Gregory S. Donahue
`Reg. No. 47,531
`DiNovo Price LLP
`7000 North MoPac Expressway
`Suite 350
`Austin, Texas 78731
`Lead Counsel for Patent Owner
`
`16
`
`

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