UNITED STATES PATENT AND TRADEMARK OFFICE
`______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`______________________
`
`MICROSOFT CORPORATION,
`
`Petitioner,
`
`v.
`
`DIRECTSTREAM, LLC,
`
`Patent Owner.
`_______________________
`IPR2018-01605, IPR2018-01606, IPR2018-01607
`Patent 7,620,800 B2
`_____________________
`
`
`PATENT OWNER DIRECTSTREAM, LLC’S
`MOTION TO EXCLUDE UNDER 37 C.F.R. §42.64
`
`
`
`______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`______________________
`
`MICROSOFT CORPORATION,
`
`Petitioner,
`
`v.
`
`DIRECTSTREAM, LLC,
`
`Patent Owner.
`_______________________
`IPR2018-01605, IPR2018-01606, IPR2018-01607
`Patent 7,620,800 B2
`_____________________
`
`
`PATENT OWNER DIRECTSTREAM, LLC’S
`MOTION TO EXCLUDE UNDER 37 C.F.R. §42.64
`
`
`
`
`TABLE OF CONTENTS
`
`I.
`
`II.
`
`STATEMENT OF OBJECTIONS .................................................................. 1
`
`LEGAL STANDARDS ................................................................................... 2
`
`III. ARGUMENT ................................................................................................... 4
`
`A. Uses of the Evidence .................................................................................. 4
`
`B. Exhibits 1074, 1077 and 1079 (Technical Documents) ............................. 6
`
`C. Exhibit 1076 (Dr. Stone Reply Declaration) .............................................. 8
`
`D. Exhibit 1075 (Dr. Homayoun Deposition Transcript) ............................... 9
`
`E. Exhibit 1078 (Dr. El-Ghazawi Deposition Transcript) ............................ 11
`
`IV. CONCLUSION .............................................................................................. 12
`
`V.
`
`CERTIFICATE OF SERVICE ...................................................................... 14
`
`VI. CERTIFICATE OF PAGE COUNT ............................................................. 15
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`i
`
`
`
`TABLE OF AUTHORITIES
`
`
`
`CASES:
`
`Aqua Prods., Inc. v. Matal,
`872 F.3d 1290 (Fed. Cir. 2017) ............................................................................. 3
`
`
`Custom Accessories v. Jeffrey-Allan Indus.,
`807 F. 2d 955 (Fed. Cir. 1986) ..................................................................... 10, 11
`
`In re: Magnum Oil Tools International, Ltd.,
`829 F.3d 1364 (Fed. Cir. 2015) ............................................................................. 3
`
`STATUTES:
`
`35 U.S.C. §316 ........................................................................................................... 3
`
`RULES:
`
`FED. R. EVID. 104 ...................................................................................................... 3
`
`FED. R. EVID. 401 ...................................................................................................1, 2
`
`FED. R. EVID. 402 ............................................................................................. passim
`
`FED. R. EVID. 403 .............................................................................................. 1, 2, 8
`
`FED. R. EVID. 702 .............................................................................................. 1, 2, 7
`
`FED. R. EVID. 703 .............................................................................................. 1, 2, 7
`
`FED. R. EVID. 705 ....................................................................................................... 2
`
`FED. R. EVID. 801 ....................................................................................................... 7
`
`FED. R. EVID. 802 ............................................................................................... 1, 2,7
`
`FED. R. EVID. 803 ...................................................................................................1, 2
`
`
`
`
`ii
`
`
`
`FED. R. EVID. 804 ...................................................................................................... 7
`
`FED. R. EVID. 805 ....................................................................................................... 7
`
`FED. R. EVID. 901 .......................................................................................... 1, 2, 3, 6
`
`REGULATIONS:
`
`37 C.F.R. §42.62 ....................................................................................................1, 2
`
`
`37 C.F.R. §42.64 ............................................................................................. 3, 4, 15
`
`
`37 C.F.R. §42.65 ........................................................................................................ 2
`
`OTHER AUTHORITIES:
`
`21A Charles Alan Wright & Arthur R. Miller, Federal Practice & Procedure,
`§5053 ...................................................................................................................... 3
`
`
`LKQ Corp. v. Clearcamp, IPR2013-00020, Paper 17 (PTAB March 15, 2013)....... 2
`
`St. Jude Medical, Inc. v. the Regents of the University of Michigan,
`
`IPR2013-00041, Paper 69 (PTAB May 1, 2014) .................................................. 3
`
`
`
`
`
`iii
`
`
`
`I. STATEMENT OF OBJECTIONS
`
`With respect to exhibits and testimony cited and relied upon by Petitioner,
`
`Patent Owner DirectStream, LLC (“Patent Owner”) hereby identifies (in numerical
`
`order by exhibit number) each specific exhibit and portion of testimony that Patent
`
`Owner requests the Board exclude from the evidentiary record of this case pursuant
`
`to 37 C.F.R. §42.62(a):
`
`Bases for
`Objection
`FRE 401-403, 702,
`703, 901, 802 &
`803
`
`Objection Made On:
`
`Dec. 2, 2019 (Paper
`No. 55)
`
`FRE 702, 401-403 Nov. 14, 2019
`(EX1075, 27:7, 65:15)
`
`
`
`FRE 401-403
`
`FRE 401-403, 702,
`703, 901, 802 &
`803
`
`Dec. 2, 2019 (Paper
`No. 55)
`
`Dec. 2, 2019 (Paper
`No. 55)
`
`FRE 702, 401-403 Oct. 4, 2019 (EX1078,
`65:21)
`
`Ex. No.
`
`1074
`
`1075
`
`1076
`
`1077
`
`1078
`
`Description
`
`Gokhale, M. and Minnich,
`R., "FPGA computing in a
`data parallel C," Proc.
`IEEE Workshop on
`FPGAs for Cust. Comp.
`Mach., 94-101 (1993)
`
`Deposition Transcript of
`Houman Homayoun,
`Ph.D. in IPR2018-01601, -
`10602, -01603, -01605, -
`01606, -01607 (November
`14, 2019)
`
`Reply Declaration of Dr.
`Harold Stone
`
`Microsoft Computer
`Dictionary Excerpt, 5th
`Edition
`
`Deposition Transcript of
`Tarik El-Ghazawi in
`IPR2018-01594, -01599, -
`01600, -01601, -01602, -
`01603, -01604, -01605, -
`
`1
`
`
`
`
`
`01606, -01607 (October 4,
`2019)
`
`Skahill, Kevin, “VHDL
`for Programmable Logic”,
`viii-xi (1996)
`
`
`1079
`
`
`
`FRE 401-403, 702,
`703, 901, 802 &
`803
`
`Dec. 2, 2019 (Paper
`No. 55)
`
`Patent Owner also asks the Board to exclude any objected-to portions of
`
`deposition testimony that Petitioner did not cite in any paper. Patent Owner moves
`
`to exclude portions of Exhibits 1075 and 1078 on this basis. See FED. R. EVID. 401
`
`and 402.
`
`II. LEGAL STANDARDS
`
`The Federal Rules of Evidence apply in an inter partes review trial, unless the
`
`Board’s IPR rules expressly state otherwise.1 See 37 C.F.R. §42.62(a); see also LKQ
`
`
`1 The IPR trial rules expressly exclude “portions of the Federal Rules of Evidence
`
`relating to criminal proceedings, juries, and other matters not relevant to [IPR]
`
`proceedings” from applying in IPR. See 37 C.F.R. §42.62(b). The IPR trial rules
`
`also modify certain terminology from the Federal Rules of Evidence to fit IPR trials.
`
`Id. at §42.62(c). Also, the IPR trial rules expressly modify the Federal Rules of
`
`Evidence to impose an affirmative obligation on testifying experts to fully disclose
`
`the facts and data underlying their expert opinions. Compare 37 C.F.R. §42.65(a)
`
`with FED. R. EVID. 705.
`
`
`
`2
`
`
`
`Corp. v. Clearcamp, IPR2013-00020, Paper 17 at 3 (PTAB March 15, 2013).
`
`Petitioner bears the burden of proof to establish the admissibility of any evidence
`
`upon which it intends to rely in this proceeding to support any asserted ground of
`
`unpatentability. See 35 U.S.C. §316(e); see generally Aqua Prods., Inc. v. Matal,
`
`872 F.3d 1290 (Fed. Cir. 2017) (en banc); In re: Magnum Oil Tools International,
`
`Ltd.,829 F.3d 1364 (Fed. Cir. 2015); see also FED. R. EVID. 104(b) and 901(a); 21A
`
`Charles Alan Wright & Arthur R. Miller, Federal Practice & Procedure, §§5053,
`
`5053.3 (2d ed. August 2019 Update).
`
`For evidence served prior to institution of trial, any objection to the evidence
`
`must be filed within ten business days of the Board’s institution decision and
`
`objections to evidence served after institution of trial must be served within five
`
`business days of service of the evidence. See 37 C.F.R. §42.64(b)(1). Objections to
`
`such evidence “must identify the grounds for the objection with sufficient
`
`particularity to allow correction in the form of supplemental evidence.” 37 C.F.R.
`
`§42.64(b)(1). An objection to the admissibility of deposition evidence must be made
`
`during the deposition and, unless the parties stipulate otherwise, evidence to cure the
`
`objection must be provided during the deposition. See 37 C.F.R. §42.64(a).
`
`Where an objection cannot be cured by supplemental evidence, no prejudice
`
`results from the failure to timely object. See, e.g., St. Jude Medical, Inc. v. the
`
`
`
`3
`
`
`
`Regents of the University of Michigan, IPR2013-00041, Paper 69 at 32-33 (PTAB
`
`May 1, 2014).
`
` “A motion to exclude evidence must be filed to preserve any objection. The
`
`motion must identify the objections in the record in order and must explain the
`
`objections.” 37 C.F.R. §42.64(c); see also PTAB Consolidated Trial Practice Guide
`
`(November 2019) at 79-80.
`
`III. ARGUMENT
`
`Patent Owner provides the following additional explanation and argument to
`
`support the above-identified objections.
`
`A. Uses of the Evidence
`
`Petitioner relies on Ex. 1074 in at least the following way:
`
`• Petitioner’s Reply to Patent Owner’s Response, Paper 49 at 16-17: to
`
`argue the content of the Halverson thesis.
`
`Petitioner relies on Ex. 1075, 65:12-17 in at least the following way:
`
`• Petitioner’s Reply to Patent Owner’s Response, Paper 49 at 36: to
`
`contend that Dr. Homayoun never contested the Board’s interpretation
`
`of “computational loop.”
`
`Petitioner relies on Ex. 1075, 27:4-12 in at least the following way:
`
`
`
`4
`
`
`
`• Petitioner’s Reply to Patent Owner’s Response, Paper 49 at 8: to
`
`contend that Dr. Homayoun testified he purportedly applied the wrong
`
`law and his entire report should therefore be given no weight.
`
`Petitioner relies on Ex. 1076 in at least the following ways:
`
`• Petitioner’s Reply to Patent Owner’s Response, Paper 49 at 16-17: to
`
`argue the content of the Halverson thesis;
`
`• Petitioner’s Reply to Patent Owner’s Response, Paper 49 at 18: to argue
`
`the disclosures of Splash2;
`
`• Petitioner’s Reply to Patent Owner’s Response, Paper 49 at 36-40: to
`
`argue the definition of “loop” and “computational loop” and the
`
`disclosures of Splash2;
`
`• Petitioner’s Reply to Patent Owner’s Response, Paper 49 at 42-43: to
`
`argue that RaPiD discloses “computational loops;” and
`
`• Petitioner’s Reply to Patent Owner’s Response, Paper 49 at 44 n. 13: to
`
`clarify Dr. Stone’s answer to a question asked in deposition.
`
`Petitioner relies on Ex. 1077 in at least the following way:
`
`• Petitioner’s Reply to Patent Owner’s Response, Paper 49 at 19 n. 5: to
`
`define the terms “data path” and “data structure.”
`
`Petitioner relies on Ex. 1078, 65:19-66:18 in at least the following ways:
`
`• Petitioner’s Reply to Patent Owner’s Response, Paper 49 at 7: to argue
`
`
`
`5
`
`
`
`what was allegedly known in the prior art to the ‘324 Patent.
`
`• Petitioner’s Reply to Patent Owner’s Response, Paper 49 at 17: to argue
`
`the disclosures of Splash2.
`
`Petitioner relies on Ex. 1079 in at least the following way:
`
`• Petitioner’s Reply to Patent Owner’s Response, Paper 49 at 7: to argue
`
`what was allegedly known in the prior art to the ‘324 Patent.
`
`B.
`
`Exhibits 1074, 1077, and 1079 (Technical Documents)
`
`Exhibits 1074, 1077, and 1079 are documents that Petitioner first served and
`
`filed along with its Reply Brief. Petitioner asserts that Exhibits 1074 and 1079 are
`
`copies of technical articles or publications. Exhibit 1077 appears to be a copy of a
`
`technical dictionary. Patent Owner timely objected to the admissibility of Exhibits
`
`1074, 1077, and 1079. See Paper 55 at 2. Petitioner did not serve supplemental
`
`information in response to Patent Owner’s objections.
`
`Patent Owner objects to the authenticity of Exhibits 1074 and 1079 and moves
`
`to exclude each of these exhibits under FED. R. EVID. 901. Petitioner failed to submit
`
`evidence to authenticate these documents in any way or demonstrate a bases for any
`
`expert to reply upon them. Thus, Exhibits 1074 and 1079 must be excluded from
`
`evidence. See FED. R. EVID. 901(a) (“To satisfy the requirement of authenticating
`
`or identifying an item of evidence, the proponent must produce evidence sufficient
`
`
`
`6
`
`
`
`to support a finding that the item is what the proponent claims it is.”) (emphasis
`
`added); see also FED. R. EVID. 702 and 703.
`
`Patent Owner further objects to Exhibits 1074, 1077, and 1079 as inadmissible
`
`hearsay and moves to exclude each of exhibits under FED. R. EVID. 802. As
`
`described in the Section above, Petitioner in its Reply cites each of these documents
`
`to prove the truth of technical matters allegedly asserted in such documents, i.e., to
`
`support Petitioner’s specific factual assertions regarding a technical issue. For this
`
`reason, each exhibit satisfies the definition of “hearsay.” See FED. R. EVID. 801(c),
`
`(d). Petitioner cannot meet its burden to show that any of these exhibits meets any
`
`exception to the hearsay rule under FED. R. EVID. 804 or 805. Thus, Exhibits 1074,
`
`1077, and 1079 must each be excluded from evidence as inadmissible hearsay under
`
`FED. R. EVID. 802.
`
`Patent Owner further objects to Exhibit 1077 as irrelevant to the patent and
`
`claim construction issues in dispute and moves to exclude it under FED. R. EVID.
`
`402. Specifically, the exhibit is extrinsic evidence pertaining to Petitioner’s
`
`proffered definitions from the Microsoft Computer Dictionary of “data structure”
`
`and “data path,” neither of which are claim terms in the patent. Instead, Petitioner
`
`appears to quibble with whether the same Microsoft Computer Dictionary’s
`
`definition of “queue” accurately used the term “data structure” when it defined queue
`
`as “A multi-element data structure…” See EX2065 at 433.
`
`
`
`7
`
`
`
`Petitioner already admitted that Patent Owner’s own documentation
`
`“characterizes a ‘stream’ as a ‘data structure,’” [Reply at 33], which is consistent
`
`with the Microsoft Computer Dictionary’s definition of queue as a data structure and
`
`also with Patent Owner’s definition and documentation of stream to reflect such a
`
`data structure. EX2111¶¶151-154 (quoting EX2065 at 433); Response at 56 (citing
`
`EX2107 at 94). Petitioner’s attempts to redefine the clear words used in a dictionary
`
`definition are nothing but an attempt to obfuscate and are wholly irrelevant to the
`
`actual claim construction issues.
`
`C.
`
` Exhibit 1076 (Dr. Stone Reply Declaration)
`
`Exhibit 1076 is Petitioner's expert's reply declaration. Patent Owner objects
`
`under FED. R. EVID. 402 and 403 specifically to paragraphs 15-17, which discuss
`
`EX1074 for the first time. During deposition, Dr. Stone admitted that discussion of
`
`EX1074 was first introduced by Petitioner in Reply. Yet, in EX1076, Dr. Stone
`
`attempts to characterize Petitioner's reply exhibit as somehow first introduced by
`
`Patent Owner in its Response. EX2176, 10:4-13:9. Discussion of EX1074 and its
`
`contents in his reply declaration is, therefore, irrelevant to any issues presented by
`
`Patent Owner and must be excluded as prejudicial in the inability for Patent Owner
`
`to respond.
`
`
`
`8
`
`
`
`D. Exhibit 1075 (Dr. Homayoun Deposition Transcript)
`
`In Reply, Petitioner cites deposition testimony from Dr. Homayoun
`
`purportedly to show that Dr. Homayoun “never offers an interpretation of
`
`‘computational loop…’” Reply, 36-37 (citing EX1075, 65:12-17). Patent Owner
`
`moves to exclude the cited testimony on the basis of “form” objections stated at
`
`EX1075, 65:15. Based on Petitioner’s Reply, the question asked is vague,
`
`ambiguous, calls for a legal conclusion, and misleading because counsel’s question
`
`applies only to paragraph 195 of Dr. Homayoun’s report. EX1075, 65:5-6, 8-10, 12-
`
`14 (excerpted below, with emphasis added):
`
`5 Q. Okay. So on the next page of
`6 Exhibit 2111, page 87, do you see paragraph 195?
`7 A. Yes, I see.
`8 Q. And in 195, you recount the Board's
`9 interpretation of the computational loop claim
`10 language; correct?
`11 A. Yes.
`12 Q. Would you agree that you don't have an
`13 opinion here saying that the Board's interpretation
`14 is incorrect?
`
`But in its Reply, Petitioner now attempts to recharacterize the question as
`
`pertaining to the entirety of Dr. Homayoun’s report, not just paragraph 195 as asked.
`
`Reply, 36. To the extent Petitioner actually intended to ask Dr. Homayoun about his
`
`entire report, the question was vague, ambiguous, and misleading and should be
`
`excluded.
`
`
`
`9
`
`
`
`To the extent Petitioner is now recharacterizing the actual testimony, the cited
`
`deposition passage should still be excluded as irrelevant under FED. R. EVID. 402
`
`because Dr. Homayoun clearly and unequivocally opines on the interpretation of
`
`computational loop outside of paragraph 195 of his report, which Petitioner never
`
`asked any questions about. EX2111¶207 (“A computational loop evaluates each
`
`piece of data multiple times, “a fixed number of times or until some condition is true
`
`or false.””). Petitioner’s attempts to now delete passages from Dr. Homayoun’s
`
`report using attorney argument to mischaracterize the record are: (1) not evidence
`
`and (2) irrelevant to the actual issues in dispute and should thus be excluded.
`
`Additionally, in Reply, Petitioner argues Dr. Homayoun’s “testimony should
`
`be given no weight,” using deposition testimony to claim that Dr. Homayoun
`
`misapplied the law, which Petitioner purposefully misstates. Reply, 8 (citing
`
`EX1075, 27:4-12). Patent Owner moves to exclude the cited testimony on the basis
`
`of “form” objections stated at EX1075, 27:7. Based on Petitioner’s Reply, the
`
`question asked is vague, ambiguous, calls for a legal conclusion, and misleading.
`
`Moreover, Petitioner argues Dr. Homayoun should have testified “[a] Skilled Artisan
`
`is presumed to be aware of the content of the prior art…” Reply, 7 (citing Custom
`
`Accessories v. Jeffrey-Allan Indus., 807 F. 2d 955, 962 (Fed. Cir. 1986)) (emphasis
`
`added). But, Custom Accessories actually states: “The person of ordinary skill is a
`
`hypothetical person who is presumed to be aware of all the pertinent prior art.”
`
`
`
`10
`
`
`
`Custom Accessories, Inc., 807 F.2d at 962 (emphasis added). Dr. Homayoun’s
`
`testimony is entirely consistent with Custom Accessories even though counsel was
`
`purposefully trying to elicit confusing testimony with a wrong legal standard and
`
`therefore the deposition passage is irrelevant to any actual issues in dispute under
`
`FED. R. EVID. 402. Compare EX1075, 27:8-12 (Dr. Homayoun testifying: “Prior
`
`relevant art. I would essentially correct it that way. Because "prior art" is open-
`
`ended, could be anything. But "prior relevant art" is what is relevant to essentially
`
`what all of these work are trying to describe.”) (emphasis added) with EX1075,
`
`27:14-28:12 (counsel for Petitioner asking Dr. Homayoun to assume a wrong legal
`
`standard to elicit a deposition “sound bite” but nevertheless was unsuccessful to get
`
`the witness to agree).
`
`E.
`
`Exhibit 1078 (Dr. El-Ghazawi Deposition Transcript)
`
`In Reply, Petitioner cites deposition testimony from Dr. El-Ghazawi
`
`purportedly to show that VHDL programming associated with FPGAs. Reply, 7, 17
`
`(citing EX1078, 65:12-17). Patent Owner moves to exclude the cited testimony on
`
`the basis of “form” objections stated at EX1078, 65:21. Based on Petitioner’s Reply,
`
`the question asked is vague, ambiguous, and calls for a speculative answer and thus
`
`should be excluded.
`
`
`
`11
`
`
`
`IV. CONCLUSION
`
`For the foregoing reasons, Patent Owner respectfully requests that the Board
`
`grants the foregoing Motion to Exclude, and grants the specific relief identified
`
`above.
`
`
`
`
`
`
`
`12
`
`
`
`Respectfully submitted,
`
`
`
`
`/Alfonso Chan/
`Alfonso Chan, Reg. No. 45,964
`achan@shorechan.com
`Joseph F. DePumpo, Reg. No. 38,124
`jdepumpo@shorechan.com
`SHORE CHAN DEPUMPO LLP
`901 Main Street, Suite 330
`Dallas, Texas 75202
`Tel: (214) 593-9110
`Fax: (214) 593-9111
`
`Sean Hsu, Reg. No. 69,477
`shsu@jvllp.com
`Rajkumar Vinnakota*
`kvinnakota@jvllp.com
`G. Donald Puckett*
`dpuckett@jvllp.com
`JANIK VINNAKOTA LLP
`8111 Lyndon B. Johnson Frwy., #790
`Dallas, Texas 75251
`Tel: (214) 390-9999
`Fax: (214) 888-0219
`* Admitted Pro Hac Vice
`
`Attorneys for Patent Owner
`DirectStream, LLC
`
`
`Dated: January 15, 2020
`
`
`
`
`
`
`
`
`
`13
`
`
`
`V. CERTIFICATE OF SERVICE
`
`Pursuant to 37.C.F.R. §§42.6(e)(4) and 42.25(b), the undersigned certifies that
`
`on January 15, 2020, a complete copy of the foregoing document was filed
`
`electronically through the Patent Trial and Appeal Board’s PTABE2E System and
`
`provided, via electronic service, to the Petitioner by serving the correspondence
`
`address of record as follows:
`
`Joseph A. Micallef
`jmicallef@sidley.com
`Scott M. Border
`sborder@sidley.com
`SIDLEY AUSTIN LLP
`1501 K. Street N.W.
`Washington, DC 20005
`
`Jason P. Greenhut
`jgreenhut@sidley.com
`SIDLEY AUSTIN LLP
`1 South Dearborn
`Chicago, IL 60603
`
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`/Alfonso Chan/
`Alfonso Chan
`Reg. No. 45,964
`Tel: (214) 593-9110
`
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`14
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`
`
`VI. CERTIFICATE OF PAGE COUNT
`
`Pursuant to 37 C.F.R. §42.24, the undersigned certifies that the foregoing
`
`Patent Owner DirectStream, LLC’s Motion to Exclude Under 37 C.F.R. §42.64
`
`contains less than 15 pages, excluding the Table of Contents, Table of Authorities,
`
`Certificate of Service, and Certificate of Page Count.
`
`Dated: January 15, 2020
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`/Alfonso Chan/
`Alfonso Chan
`Reg. No. 45,964
`Tel: (214) 593-9110
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`15
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