IPR TELECONFERENCE 6-21-18
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`Page 1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` LG ELECTRONICS, INC., LG ELECTRONICS U.S.A., INC., LG
` ELECTRONICS MOBILECOMM U.S.A., LG ELECTRONICS MOBILE
` RESEARCH U.S.A. LLC, AND LG ELECTRONICS ALABAMA, INC.
` Petitioner
` v.
` FUNDAMENTAL INNOVATION SYSTEM INT'L, LLC
` Patent Owner
`
` IPR2018-00493
` IPR2018-00495
` IPR2018-00508
`
`Reported by Carrie LaMontagne, CSR
`Job No. 143973
`
`TSG Reporting - Worldwide 877-702-9580
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` IPR TELECONFERENCE 6-21-18
`A P P E A R A N C E S
`(all appearances via telephone):
`
` HAYNES AND BOONE
` Attorneys for Petitioner:
` 2505 N. Plano Road
` Richardson, Texas 75082
` BY: GREGORY HUH, ESQ.
` ADAM FOWLES, ESQ.
`
` IRELL & MANELLA
` For Patent Owner:
` 1800 Avenue of the Stars
` Los Angeles, California 90067
` BY: ANNITA ZHONG, ESQ.
` MICHAEL FLEMING, ESQ.
` JASON SHEASBY, ESQ.
`
`BEFORE: FOR THE PATENT TRIAL AND APPEAL BOARD:
` JUDGE ARTHUR M. PESLAK
` JUDGE LYNNE E. PETTIGREW
` JUDGE JON TORNQUIST
` JUDGE BRIAN WHITE
` JUDGE CHRISTOPHER L. OGDEN
`
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` IPR TELECONFERENCE 6-21-18
` JUDGE PESLAK: All right. And who is on the
`line for the patent owner?
` MS. ZHONG: For the patent owner, this is
`Annita Zhong, and also with me is Mr. Michael Fleming and
`Mr. Jason Sheasby.
` JUDGE PESLAK: Okay. Just so the record is
`clear, when you begin to speak, please identify
`yourself.
` The board received an e-mail from Petitioner on
`June 12 requesting authorization to file a five-page
`reply to Patent Owner's preliminary response in each of
`the three identified IPRs. The e-mail indicates that
`Patent Owner opposes.
` We'll hear from the petitioner first. If your
`argument is the same for all three IPRs, there's no need
`to repeat it; but if there's something specific for one
`of the IPRs, please make that clear on the record.
` So starting with the petitioner, can you please
`tell us the facts that you contend support a finding of
`good cause under 42 CFR, Section 108, Paragraph C to
`allow the filing of a reply.
` MR. HUH: Yes, your Honor. This is
`Gregory Huh on behalf of Petitioner. And under the
`circumstances, we believe there are three reasons why
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` IPR TELECONFERENCE 6-21-18
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` Thursday, June 21, 2018
` 3:00 p.m.
`
` Telephone proceeding held before the United
`States Patent and Trademark Office before Carrie
`LaMontagne, a certified shorthand reporter for the
`states of California and Oklahoma.
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` IPR TELECONFERENCE 6-21-18
` P R O C E E D I N G S
` JUDGE PESLAK: Good afternoon. This is Judge
`Peslak. This is a conference call on three IPRs, IPR
`2018-0493, IPR 20018-0495, IPR 20018-000508. On the
`call with me are Judge Pettigrew, Judge Tornquist, and
`Judge Ogden.
` For the record the spelling of our names, my name
`is Peslak, P, as in Peter, E-S-L-A-K. Judge Pettigrew,
`is P, as in Peter, E-T-T-I-G-R-E-W. Judge Tornquist, T,
`as in Thomas, O-R-N-Q-U-I-S-T, and Judge Ogden,
`O-G-D-E-N.
` I understand there's a court reporter. Who
`arranged for the court reporter?
` MR. HUH: Yes, your Honor. This is
`Gregory Huh on behalf of Petitioner LG Electronics, and
`we arranged for the court reporter.
` JUDGE PESLAK: So we'll ask that you file the
`transcript as an exhibit in all three cases as soon as
`possible.
` MR. HUH: Will do, your Honor.
` JUDGE PESLAK: So who is on the line for
`Petitioner?
` MR. HUH: Yes, on behalf of Petitioner, this
`is Gregory Huh and I also have Mr. Adam Fowles.
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` IPR TELECONFERENCE 6-21-18
`there is good cause for us to have leave to file a reply
`to Patent Owner's preliminary response.
` The first reason is that it wasn't foreseen that
`Patent Owner would have filed the deposition transcript
`of Mr. Garney who was not LG Electronics expert, and LG
`Electronics was not a part to the proceeding to which
`that transcript pertains.
` Had LG Electronics filed this transcript with its
`petition, it wouldn't have been able to produce
`Mr. Garney for cross-examination during the proceeding.
`Therefore, Petitioner could not have submitted this
`transcript along with petition at the early stage of the
`proceeding.
` The second reason why there is good cause is that
`although Patent Owner argues that LG Electronics was
`provided this transcript during litigation, LG
`Electronics' counsel for litigation is different than
`the counsel for IPRs in all of these three cases.
` And at the time of the filing of the petition, IPR
`counsel was not, was not aware of this transcript at all
`existing. Moreover, there's a protective order
`prohibiting LG Electronics' litigation counsel from
`sharing these documents with us and for us to produce
`them outside of litigation.
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`Page 8
` IPR TELECONFERENCE 6-21-18
`expectation of success in the combination of Shiga and
`the Dougherty reference, which is a primary reference in
`all of these proceedings that were filed by Petitioner
`LG Electronics.
` JUDGE PESLAK: Counsel, I think you're
`deviating from the issue here, which is good cause.
`You're getting into the merits.
` MR. HUH: Yes. And the point is, your Honor,
`that what Patent Owner has done is they've omitted
`relevant testimony from Mr. Garney that provides proper
`context to evaluate that testimony and recognize that,
`in fact, it doesn't stick for the proposition that they
`actually assert that it stands for.
` So we believe that in order to give the board a
`full appreciation of what Mr. Garney's testimony stands
`for and to allow the board to properly weigh that
`evidence as it pertains to the claims and the prior art,
`which is how Patent Owner had argued in their POPR, we
`would ask that we have an opportunity to file a reply to
`address the arguments raised by Patent Owner in
`connection with Mr. Garney's testimony.
` For those three reasons, your Honor, we think that
`there are distinct reasons why we should, in fact, have
`an opportunity here to address the testimony of
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` IPR TELECONFERENCE 6-21-18
` So we could not have filed Mr. Garney's testimony
`at the petition stage since we didn't have it in hand
`and we were not aware of it. For that reason there's
`good cause, and we should actually have an opportunity
`now to reply to the filed transcript by Patent Owner.
` Third, and I think probably most importantly, is
`that it would inform the board's analysis and put proper
`context from Mr. Garney's testimony. And this is
`important because when you put Mr. Garney's testimony in
`context, it shows that Mr. Garney was talking about an
`SE1 signal occurring after enumeration, whereas in the
`context of the claims of the patent, they require
`without enumeration.
` What that means is that the claims as the SE1
`states are occurring before enumeration, and this is the
`same context for Shiga. Shiga provides an SE1 signal,
`which is Exhibit 1008, and that signal occurs before
`enumeration. The petition never argued that the SE1
`signal would be utilized after enumeration, which means
`that Mr. Garney's testimony, which pertains to events
`occurring after enumeration, has no bearing.
` I also want to note that because Shiga itself does,
`in fact, provide an SE1 signal followed by USB
`communication, it demonstrates that there's an
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` IPR TELECONFERENCE 6-21-18
`Mr. Garney.
` JUDGE PESLAK: Okay. Patent Owner.
` MS. ZHONG: This is Annita Zhong. I'm going to
`be arguing on behalf of Patent Owner.
` What I have heard is an evolving story. In the
`e-mail to the board the petitioner said they should be
`allowed to file a reply because Mr. Garney's testimony
`is hearsay. Now they have totally abandoned that
`argument because they -- I think they realized that the
`objection to evidence should not occur -- does not occur
`until ten days after institution. So the argument to
`the evidence itself on hearsay ground is basically
`premature.
` Second of all, regarding the good cause or more
`likely its foreseeability, I would say it's totally
`foreseeable based on their own argument, which is, I
`quote -- using IPR2018-508 as an example, page 23 to 24,
`they say SE1 should be used because its obvious
`beneficial predictable results. They say SE1 should be
`used because its suitable for USB signaling. They say
`SE1 should be because it's logical and [indiscernible].
` In response to those arguments it is foreseeable
`that Patent Owner is going to raise to counter each of
`those points. And Mr. Garney's testimony directly
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`undermines those points, so it's fair -- it's
`foreseeable that Patent Owner is going to raise such
`testimony by another neutral expert.
` JUDGE PESLAK: What were you just reading
`from?
` MS. ZHONG: I'm reading from the petition,
`page 23 and 24 of IPR2018-00508 petition.
` MR. HUH: To be clear -- this is Gregory Huh,
`Petitioner never argued that the SE1 signal will be
`occurring after enumeration and that's exactly what
`Mr. Garney's testimony pertains to.
` MS. ZHONG: Well, first of all, this is wading
`into the merits of the argument. Second of all, their
`petition never says that SE1 is going to occur before or
`after enumeration. That never appeared --
` JUDGE PESLAK: We're all getting too far into
`the merits. Can you get back to why Patent Owner
`doesn't believe there's good cause here.
` MS. ZHONG: Okay. Regarding the second, to
`say that they are not aware of the Garney testimony,
`that is just false. It was provided to them. They
`don't deny that LG is in possession of that transcript
`two to three weeks before filing it, and that transcript
`is not sealed. So I don't see what prevents the LG IPR
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` IPR TELECONFERENCE 6-21-18
`know whether you would have thought -- now you're going
`to look for that difference even though it has nothing
`to do with their petition. Never raised it.
` Third of all, if your Honor wants to hear why it is
`not hearsay, I'm happy to talk about it. But it was
`also explained why it was not hearsay in our POPR, in
`the IPR2018-00508.
` JUDGE PESLAK: Okay. I don't think that's
`necessary.
` MR. HUH: Your Honor, this is Gregory Huh. If
`I may respond on a few points.
` JUDGE PESLAK: Just to clarify the record.
`Don't get into the merits, please.
` MR. HUH: Yes, your Honor.
` So with respect to the hearsay, that was our first
`point that we raised in our initial discussion was the
`hearsay issue, we did not abandon that as Counsel has
`argued.
` Second, with respect to us not being aware, the
`fact is that we were not aware. IPR counsel was not
`aware. Even now we don't have possession of that
`testimony. We reached out to litigation counsel a few
`days ago and we asked for the testimony to be given to
`us. They said it was subject to protective order and
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`counsel receiving that and reviewing that. But in any
`event, the petition is filed on behalf of LG, and LG was
`in possession of that transcript before.
` So the third point is we feel that just by arguing
`the merits on the phone just now, the petitioner has
`achieved what they could not have done under general
`plastics. Basically, what they have noticed is they
`found the board's prior position in IPR2018-00111 and
`they realize the gap in the petition, the logic, so
`they're trying to make new arguments, and they already
`did that by arguing to your Honors the alleged
`differences between the Garney testimony and what their
`petition is.
` Those differences -- the alleged difference of what
`they are actually arguing does not appear in the
`petition, and so basically they've already achieved
`that, what they could not do with general plastics,
`which is by or through a petition, and to make new
`arguments and make it better.
` We find that's totally prejudicial for the patent
`owner. And I don't know what the remedy is right now
`because the cat is out of the bag, and I don't know how
`that is going to influence your Honor's positions from
`this point onward because you've heard it. And I don't
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` IPR TELECONFERENCE 6-21-18
`they could not give it us to. This is a fact.
` We could not have raised any arguments pertaining
`to this testimony of Mr. Garney at the petition stage.
`We were not aware even, and now we cannot obtain the
`full transcript. And what we would ask is that if
`actually Patent Owner does have it, we would ask that --
`and if Patent Owner has authority to file it, that they
`would file the full transcript and can get the record,
`that the board has full knowledge of everything in
`regard to this prior event, not a partial snippet of the
`record. We then we would have an opportunity to
`actually provide context for the board.
` We think it's reasonable that the board have
`context and understand what Patent Owner is arguing, how
`they are pulling out specific quotes that don't stand
`for propositions that they're making.
` MS. ZHONG: Your Honor, this is Annita Zhong.
` MR. HUH: Okay. Give us a couple minutes
`here.
` (Pause in the proceedings.)
` JUDGE PESLAK: Counsel, this is Judge Peslak
`back again. We're going to take these matters under
`advisement. So if you can get us the transcript as soon
`as possible, and we can review what both of you have
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` REPORTER'S CERTIFICATE
`
` I, Carrie LaMontagne, Certified Shorthand
`Reporter within and for the States of California and
`Oklahoma, License Nos. 13393 and 1976, respectively, do
`hereby certify that the foregoing proceeding was
`reported by me on 21st June, 2018, and was thereafter
`transcribed with computer-aided transcription; that the
`foregoing is a full, complete, and true record of said
`proceedings.
` I further certify that I am not of counsel or
`attorney for either or any of the parties in the
`foregoing proceedings and caption named or in any way
`interested in the outcome of the cause in said caption.
` IN WITNESS WHEREOF, I have hereunto set my
`hand and official seal this 21st day of June, 2018.
`
`____________________________
`CARRIE LAMONTAGNE, CSR
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`said today and make our decision in all three cases.
` MS. ZHONG: This is Annita Zhong on behalf of
`Fundamental. I just want to point out one more fact.
` JUDGE PESLAK: We don't really need anything
`else. Thank you.
` MR. HUH: Thank you, your Honor. We
`appreciate it.
` MS. ZHONG: Thank you, your Honor.
` JUDGE PESLAK: Thank you.
` (Deposition concluded at 3:17 p.m.)
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