`______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________
`
`Canon Inc., Canon U.S.A., Inc., and Axis Communications AB,
`
`Petitioners,
`
`v.
`
`Avigilon Fortress Corporation,
`
`Patent Owner.
`______________________
`
`Case No. IPR2019-00314
`
`U.S. Patent No. 7,932,923
`______________________
`
`
`PATENT OWNER’S OPPOSITION TO PETITIONERS’ MOTION FOR
`AUTHORIZATION TO COMPEL TESTIMONY AND/OR DOCUMENTS
`
`
`
`
`Patent Owner’s Opp. to Petitioners’ Mot. for Auth. to Compel Test. and/or Docs.
`IPR2019-00314
`
`I.
`II.
`
`B.
`
`C.
`
`D.
`
`TABLE OF CONTENTS
`INTRODUCTION ......................................................................................... 1
`PETITIONERS FAILED TO COMPLY WITH THE
`REGULATION’S REQUIREMENTS AND THE BOARD’S
`INSTRUCTIONS. .......................................................................................... 1
`III. PETITIONERS’ REQUESTED DISCOVERY IS NOT IN THE
`INTEREST OF JUSTICE ............................................................................. 2
`A.
`There is only a mere possibility and a mere allegation that useful
`information will be discovered. (Factor 1) ............................................ 3
`Factor 2 is neutral and not a basis to grant the motion. (Factor 2)
` ............................................................................................................... 6
`Petitioners fail to show that the requested information is not
`available through other means. (Factor 3) ............................................. 6
`The discovery instructions are not easy to understand. (Factor 4)
` ............................................................................................................... 8
`The discovery instructions are overly burdensome. (Factor 5) ............. 9
`E.
`IV. CONCLUSION ............................................................................................ 10
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`Patent Owner’s Opp. to Petitioners’ Mot. for Auth. to Compel Test. and/or Docs.
`IPR2019-00314
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`PATENT OWNER’S EXHIBIT LIST
`
`Description
`
`Exhibit
`No.
`2001 Declaration of Michael W. De Vries in Support of Unopposed Motion
`to Appear Pro Hac Vice on Behalf of Patent Owner Avigilon Fortress
`Corporation.
`
`2002 Declaration of Adam R. Alper in Support of Unopposed Motion to
`Appear Pro Hac Vice on Behalf of Patent Owner Avigilon Fortress
`Corporation.
`
`2003 Declaration of Akshay S. Deoras in Support of Unopposed Motion to
`Appear Pro Hac Vice on Behalf of Patent Owner Avigilon Fortress
`Corporation.
`
`37 C.F.R. § 1.132 Declaration of Kenneth A. Zeger (excerpt of U.S.
`Patent No. 7,868,912 Reexamination).
`
`Thomas Olson & Frank Brill, Moving Object Detection & Event
`Recognition Algorithms for Smart Cameras, 1 PROC. 1997 IMAGE
`UNDERSTANDING WORKSHOP 159-175 (1997).
`
`Jonathan D. Courtney, Automatic Video Indexing Via Object Motion
`Analysis, 30(4) PATTERN RECOGNITION 607-625 (1997).
`
`2007 U.S. Patent No. 6,628,835 to Brill et al.
`
`2008 Young Francis Day, et al, Spatio-Temporal Modeling of Video Data
`for On-Line Object-Oriented Query Processing, Proceedings of the
`International Conference on Multimedia Computing and Systems 98-
`105 (1995).
`
`Forouzan Golshani & Nevenka Dimitrova, A Language for Content-
`Based Video Retrieval, 6 MULTIMEDIA TOOLS AND APPLICATIONS,
`289-312 (1998).
`
`
`2004
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`2005
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`2006
`
`2009
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`ii
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`Patent Owner’s Opp. to Petitioners’ Mot. for Auth. to Compel Test. and/or Docs.
`IPR2019-00314
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`Description
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`Exhibit
`No.
`2010
`
`IPR2018-00138; IPR2018-00140, Ex. 2009 (Grindon Dep. Transcript
`Aug. 15, 2018).
`
`2011 Declaration of Jennifer A. Babbitt.
`
`SearchWorks Catalog Entry for Thomas Olson & Frank Brill, Moving
`Object Detection & Event Recognition Algorithms for Smart Cameras,
`1 PROC. 1997 IMAGE UNDERSTANDING WORKSHOP 159-175 (1997).
`
`Scanned Cover and Front Matter of Jonathan D. Courtney, Automatic
`Video Indexing Via Object Motion Analysis, 30(4) PATTERN
`RECOGNITION 607-625 (1997)
`
`2014 MRC Standards Wikipedia Search.
`
`2015 Declaration of Jennifer A. Babbitt for Sur-Reply.
`
`LinkedIn Profile of Marilyn McSweeney.
`
`2017 Declaration of Jennifer A. Babbitt in Support of Patent Owner’s
`Opposition to Petitioner’s Motion for Authorization to Compel
`Testimony and/or Documents.
`
`
`2012
`
`2013
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`2016
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`iii
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`I.
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`Patent Owner’s Opp. to Petitioners’ Mot. for Auth. to Compel Test. and/or Docs.
`IPR2019-00314
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`INTRODUCTION
`Patent Owner Avigilon Fortress Corporation (“Patent Owner”) submits this
`
`Opposition to Petitioner Canon Inc., Canon U.S.A., Inc., and Axis Communications
`
`AB’s (collectively, “Petitioners”) Motion for Authorization to Compel Testimony
`
`and/or Documents (the “Motion”) dated August 16, 2019 (Paper 18). Patent Owner
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`respectfully requests that the Board deny the Motion, which seeks purely
`
`hypothetical and irrelevant information, as would significantly burden Patent Owner
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`by forcing it to engage in this meritless discovery process.
`
`II.
`
`PETITIONERS FAILED TO COMPLY WITH THE REGULATION’S
`REQUIREMENTS AND THE BOARD’S INSTRUCTIONS.
`Under 37 C.F.R. § 42.52(a)(1), a party seeking to compel testimony must
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`“identify the witness by name or title.” Additionally, the Board instructed Petitioners
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`to “identify as specifically as possible exactly what testimony and documents it is
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`seeking from each of the third parties.” Ex. 1050 at 20:19-21:5. Petitioners have
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`not complied with any of these directives, and Patent Owner submits that their
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`request should be denied for at least that reason. See Motion at 3; id. at Exs. A and
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`B. First, Petitioners clearly do not satisfy Rule 42.52(a)(1) because they do not
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`identify the witnesses, either by name or title, at the Massachusetts Institute of
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`Technology (“MIT”) library or the Library of Congress (“LOC”) from whom they
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`seek to obtain testimony. Id; see, e.g., Motion at 1 (“Petitioners are seeking to
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`1
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`Patent Owner’s Opp. to Petitioners’ Mot. for Auth. to Compel Test. and/or Docs.
`IPR2019-00314
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`subpoena these libraries to address Patent Owner’s challenge to the public
`
`accessibility of the asserted references.”) (emphasis added). This is in contrast with
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`the cases cited by Petitioner, such as Kaz USA, Inc. v. Exergen Corp., IPR2016-
`
`01437, Paper 15 at 3 (PTAB May 16, 2017), where a petitioner identified the
`
`librarian that would be submitting a declaration. Indeed, as explained below,
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`Petitioners have done nothing to demonstrate that there in fact is anyone at MIT or
`
`the LOC that can provide the requested information, regarding the particular
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`practices in the timeframes that are relevant to the issues in this case.
`
`III. PETITIONERS’ REQUESTED DISCOVERY IS NOT IN THE
`INTEREST OF JUSTICE
`There is a strong public policy to limit discovery in administrative trial
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`proceedings. See Bloomberg Inc. v. Markets-Alert Pty. Ltd., CBM2013-00005,
`
`Paper 32 at 11 (PTAB May 29, 2013). As such, the Board shall be “conservative in
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`granting leave for additional discovery,” Microsoft Corp. v. Proxyconn, Inc.,
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`IPR2012-00026, Paper 32 at 4, for when the petitioner satisfies the burden of
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`showing that the additional discovery it seeks is in the “interests of justice.” See 37
`
`C.F.R. §§ 42.20(c), 42.51(b)(2)(i); see also 35 U.S.C. § 316(a)(5). The five Garmin
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`factors aid the Board in determining whether additional discovery serves the
`
`interests of justice. Garmin Int’l, Inc. v. Cuozzo Speed Techs. LLC, IPR2012-00001,
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`2
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`Patent Owner’s Opp. to Petitioners’ Mot. for Auth. to Compel Test. and/or Docs.
`IPR2019-00314
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`Paper 26 at 6-7 (PTAB Mar. 5, 2013) (precedential). Here, four of the five Garmin
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`factors weigh against the Petitioners.
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`A. There is only a mere possibility and a mere allegation that useful
`information will be discovered. (Factor 1)
`Petitioners fail to show “beyond speculation that something useful will be
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`uncovered” with their discovery requests. Garmin, Paper 26 at 7. The Board in
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`Garmin made clear that “useful . . . does not mean merely ‘relevant’ and/or
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`‘admissible.’” Id.; see also Bloomberg Inc., Paper 32 at 5.
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`The Petition sets the boundaries of what is “useful” to Petitioners’ arguments.
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`As to Dimitrova, the only allegation of public availability in the Petition is that
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`“Dimitrova was published in the ACM Transactions on Information Systems, Vol.
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`13, No. 4, in October 1995.” Paper 1 at 3 (emphasis added).1 But Petitioners’
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`discovery requests is not tailored to information relevant to their assertion.
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`Petitioners seek documents that hypothetically would show that Dimitrova was
`
`
`1 The Petition also relies on Brill to challenge the claims in the ’923 patent. Paper
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`1 at 3. Petitioners claim that Brill was published in the Proceedings of Image
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`Understanding Workshop, Vol. 1, published December 1998. Paper 1 at 4; Ex.
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`1007, ¶¶30-33. Petitioners state they are not seeking information allegedly
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`related to the public accessibility of Brill. Motion at 1, fn. 1.
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`3
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`“received and made available to the public by the MIT Libraries before October
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`1999” and testimony that hypothetically would show how Dimitrova was “made
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`publicly available by MIT Libraries before October 1999.”2 Motion at Exhibit A
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`(emphasis added). But there is no reason to believe that information responsive to
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`Petitioners’ request would be relevant to the allegations in the Petition, which is over
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`four years earlier than the date identified in the Motion. That is, Petitioners have
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`done nothing to ensure that the libraries can and will provide pre-October-1995
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`information. In fact, the information Petitioners request do not indicate that the MIT
`
`library has information on when Dimitrova was “published”—the only allegation
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`made as to Dimitrova in the Petition. See Paper 1 at 3. As a result, the likelihood
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`that any information returned will be irrelevant to Petitioners’ assertions is high,
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`wasting time on all sides and burdening Patent Owner as a result of Petitioners’
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`misguided quest. In a similar case, the Board denied a motion for additional
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`discovery because there was no evidence that “the historical information even
`
`exists” regarding activities before August 2000, which was only fourteen years
`
`before the request, in contrast to the twenty-four year gap at issue here. Alt. Legal
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`2 Petitioners make the same request regarding the LOC, and so the following
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`argument applies equally to Petitioners’ proposed subpoena to the LOC.
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`4
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`Patent Owner’s Opp. to Petitioners’ Mot. for Auth. to Compel Test. and/or Docs.
`IPR2019-00314
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`Sols. Inc. v. Emp’t Law Compliance Inc., IPR2014-00562, Paper 22, at 3-4, 5 (PTAB
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`Dec. 23, 2014).
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`More fundamentally, Petitioners simply have failed to show that there is more
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`than a mere possibility that useful information will be discovered because the Motion
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`does nothing at all to establish that there is anyone at MIT or the LOC that can and
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`will testify as to the relevant information on or before October 1995 (or October
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`1999, for that matter), or that any of the documentary evidence they request exists.
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`The existence of such a witness and testimony is doubtful, given that it is now
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`twenty-four years after the timeframe in question. The only examples Petitioners
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`cite regarding MIT are a declaration from an employee who began working there in
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`2016, and one from an employee who no longer works at MIT and therefore will not
`
`be put up for deposition. Kaz, Ex. 1027; Google Inc. v. CreateAds LLC, IPR2014-
`
`00200 (PTAB Nov. 27, 2013), Ex. 1007; Ex. 2016 (LinkedIn Profile of Marilyn
`
`McSweeney showing retirement from MIT in December 2016). All Petitioners have
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`established is that MIT allegedly will not provide a declaration voluntarily, and that
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`the LOC apparently did not respond at all. Motion at 3-4.
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`Further, of the three references for which Petitioners request discovery, only
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`one (Dimitrova) is at issue in this case. Kellogg and Flinchbaugh are not at issue in
`
`this IPR and Petitioners’ baseless attempt to seek discovery on them from two
`
`different libraries, including at least five categories of documents and substantial
`5
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`IPR2019-00314
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`deposition testimony, and should be denied at least for those reasons. Motion, Exs.
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`A and B. Further, the LOC is completely irrelevant to Petitioners’ assertions, as they
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`have not argued public availability at the LOC for any reference, and that issue is
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`not in the case. Petitioners’ Motion should be denied for that reason as well.
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`Nor is the public availability of Flinchbaugh at issue in this case. The Petition
`
`makes no mention of Flinchbaugh whatsoever, let alone does it, or any other
`
`pleading from Petitioners, argue for Flinchbaugh’s public availability.
`
`B.
`Factor 2 is neutral and not a basis to grant the motion. (Factor 2)
`At this time, Petitioners’ requests do not appear to seek legal positions or the
`
`underlying basis for any legal positions, but Patent Owner reserves the right to raise
`
`the issue if Petitioners modify their requests. Petitioners, however, cite to no case
`
`where mere compliance with Factor 2 justifies granting a motion for additional
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`discovery.
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`C.
`
`Petitioners fail to show that the requested information is not
`available through other means. (Factor 3)
`Petitioners claim “MIT has indicated to Petitioners that it will only provide a
`
`declaration for a reference in response to a subpoena.” Motion at 6. But Petitioners
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`do not provide any evidence to support that claim, and two IPRs that Petitioners cite
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`to demonstrate that that is not MIT’s policy. In CreateAds, Paper 1, Ex. 1007, the
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`petitioners included a declaration from an MIT librarian with the petition and
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`6
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`Patent Owner’s Opp. to Petitioners’ Mot. for Auth. to Compel Test. and/or Docs.
`IPR2019-00314
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`without requiring a subpoena.3 Also, in Alternative Legal Solutions, Inc., the patent
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`owner obtained a declaration from an MIT librarian without a subpoena as well. See
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`IPR2014-00562, Exhibit 2029; see also id. Paper 18 at 1 (“Ms. Marilyn McSweeney,
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`an MIT librarian, voluntarily provided a sworn declaration.”) (emphasis added).
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`This shows that MIT does not necessarily require a subpoena for the discovery
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`Petitioners seek.
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`Petitioners also claim that a copy of Dimitrova is found at the University of
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`California Los Angeles Science & Engineering Library (“UCLA”) (Paper 11 at 5
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`(arguing “Dimitrova was publicly disseminated, as it was received by at least three
`
`different institutions (UCLA, Library of Congress, and MIT)” (citations omitted);
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`Ex. 1007 ¶12 (Florio Declaration); see also Ex. 3002 (seeking permission to compel
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`testimony or documents from the University of California Los Angeles Science &
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`Engineering Library) but provide no evidence or describe any efforts made to obtain
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`a declaration from UCLA without a subpoena, and so have failed completely to
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`establish that their request complies with Factor 3. See generally, Motion.
`
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`3 Petitioners’ Motion to Submit Supplemental Information, Paper 19, improperly
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`attempts to file this declaration (Ex. 1048) in the instant proceeding.
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`7
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`Patent Owner’s Opp. to Petitioners’ Mot. for Auth. to Compel Test. and/or Docs.
`IPR2019-00314
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`D. The discovery instructions are not easy to understand. (Factor 4)
`Instructions and questions should be easily understandable so that the
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`responder can answer efficiently, accurately, and confidently. Bloomberg, Paper 32
`
`at 5. Petitioners misunderstand this requirement and assert that because MIT has
`
`provided declarations regarding public availability in the past, it “should be able to
`
`do so again in this proceeding” and “[t]he same should be true for the LOC.” Motion
`
`at 7. MIT’s prior willingness to provide declarations, however, does not speak to
`
`how easy Petitioners’ discovery instructions are to understand. For example,
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`Petitioners ask for “documents reflecting the authenticity of Kellogg, Dimitrova, and
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`Flinchbaugh” but do not explain how MIT would prove the authenticity of a
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`document or that anyone at MIT would know how to perform the proper analysis
`
`regarding the legal question of authenticity. Also, Petitioners’ instructions are not
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`sufficiently understandable because they failed to identify the intended party to be
`
`deposed or the specific documents it requests. Arm Ltd. v. Complex Memory, LLC,
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`IPR2019-00053, 00058, Paper 6 at 9-10 (PTAB Jan. 31, 2019) (denying a request
`
`file a motion for additional discovery because the instructions fail to identify the
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`witness and documents with specificity). Moreover, Petitioners’ instructions for
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`“[r]esponsive documents” is overly broad in scope and thus, difficult for the
`
`responder to understand. See id. (finding “limited communications” not specific
`
`enough for the responder to easily understand).
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`
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`8
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`Patent Owner’s Opp. to Petitioners’ Mot. for Auth. to Compel Test. and/or Docs.
`IPR2019-00314
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`E.
`The discovery instructions are overly burdensome. (Factor 5)
`“Requests must not be overly burdensome . . . . The burden includes financial
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`burden, burden on human resources, and burden on meeting the time schedule of the
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`trial.” Bloomberg, Paper 32 at 5. Petitioners fail to show that the discovery they
`
`seek from MIT and the LOC are not overly burdensome. Instead, they make baseless
`
`assertions that because MIT has provided declarations regarding public availability
`
`in the past, it “should be able to do so again in this proceeding” and “[t]he same
`
`should be true for the LOC.” Motion at 7.
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`Petitioners’ discovery request is overly burdensome. First, merely identifying
`
`the broad categories of discovery Petitioners’ seek is too broad in scope, and thus
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`Petitioners’ request for “responsive documents” is overly burdensome. See Arm
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`Ltd., Paper 6 at 9 (finding instructions for “limited communications” a category that
`
`is too broad in scope). Second, besides suggesting “checkouts and/or copies” as
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`records allegedly showing public access, Petitioners have not narrowly tailored the
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`list of documents or specified the relevant time period they claim would be
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`responsive to the remaining requests, which will require a burdensome expenditure
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`of human resources for the library to divine what is a “responsive document.”
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`Motion, Exs. A and B. Third, Petitioners’ instructions are unduly broad and
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`burdensome because Petitioners have not complied with Rule 42.52(a) and have not
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`identified the witness they seek to depose. This will cause burden and delay because
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`9
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`Patent Owner’s Opp. to Petitioners’ Mot. for Auth. to Compel Test. and/or Docs.
`IPR2019-00314
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`it places an obligation on the libraries to expend financial and human resources to
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`determine who, if anyone, can testify to the library shelving and recording practices
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`in October 1995—a burden that the regulations place on the party seeking the
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`discovery, not the subpoenaed entity. See Bloomberg, Paper 32 at 9.
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`Also, Petitioners’ apparent explanation as to why they seek to compel
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`testimony and production of documents regarding references not at issue in this case
`
`(Dimitrova and Flinchbaugh) is puzzling and misplaced. Motion at 7-8. The LOC
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`for example, is more burdened, not less burdened, by having to respond to two
`
`subpoenas (one in connection with each IPR) instead of one; at a minimum, there is
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`no reduction in burden by requesting irrelevant information. Moreover, Petitioners’
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`instructions seeking irrelevant information on references unrelated to this
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`proceeding from two different libraries is not “sensible and responsibly tailored
`
`according to a genuine need,” and thus unduly burdensome. Garmin, Paper 26 at
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`14.
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`Lastly, Petitioners fail to explain why they discovery from both the MIT
`
`library and the LOC when the MIT library allegedly possesses information on all
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`three references. See Motion at 3, Ex. A.
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`IV. CONCLUSION
`Patent Owner respectfully requests the Board deny Petitioners’ Motion.
`
`
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`10
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`Patent Owner’s Opp. to Petitioners’ Mot. for Auth. to Compel Test. and/or Docs.
`IPR2019-00314
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`Dated: August 23, 2019
`
`
`
`
`
`By:
`
`
`
`
`
`Reza Dokhanchy (Reg. No. 62,795)
`KIRKLAND & ELLIS LLP
`555 California Street
`San Francisco, CA 94104
`Telephone: 415-439-1400
`Facsimile: 415-439-1500
`reza.dokhanchy@kirkland.com
`
`Adam R. Alper (pro hac vice)
`KIRKLAND & ELLIS LLP
`555 California Street
`San Francisco, CA 94104
`Telephone: 415-439-1400
`Facsimile: 415-439-1500
`adam.alper@kirkland.com
`
`Back-Up Counsel for Patent Owner
`Avigilon Fortress Corporation
`
`
`
`Respectfully submitted,
`
`/s/ Eugene Goryunov/
`Eugene Goryunov (Reg. No. 61,579)
`KIRKLAND & ELLIS LLP
`300 North LaSalle
`Chicago, IL 60654
`Telephone: 312-862-2000
`Facsimile: 312-862-2200
`
`
`Lead Counsel for Patent Owner
`Avigilon Fortress Corporation
`
`Akshay S. Deoras (pro hac vice)
`KIRKLAND & ELLIS LLP
`555 California Street
`San Francisco, CA 94104
`Telephone: 415-439-1400
`Facsimile: 415-439-1500
`akshay.deoras@kirkland.com
`
`Michael W. De Vries (pro hac vice)
`KIRKLAND & ELLIS LLP
`333 South Hope Street
`Los Angeles, CA 90071
`Telephone: 213-680-8400
`Facsimile: 213-680-8500
`michael.devries@kirkland.com
`
`
`
`11
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`Patent Owner’s Opp. to Petitioners’ Mot. for Auth. to Compel Test. and/or Docs.
`IPR2019-00314
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`CERTIFICATE OF SERVICE
`The undersigned hereby certifies that a copy of the foregoing PATENT
`
`OWNER’S OPPOSITION TO
`
`PETITIONERS’ MOTION
`
`FOR
`
`AUTHORIZATION TO COMPEL TESTIMONY AND/OR DOCUMENTS,
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`and all associated exhibits was served on August 23, 2019 via electronic service on
`
`lead and back up counsel:
`
`
`Axis Communications AB
`Lead Counsel
`
`C. Gregory Gramenopoulos (Reg. No.
`36,532)
`Finnegan, Henderson, Farabow,
`Garrett & Dunner LLP
`901 New York Avenue, NW
`Washington, DC 20001-4413
`Telephone: 202-408-4263
`Facsimile: 202-408-4400
`gramenoc@finnegan.com
`
`
`
`Canon Inc. and Canon U.S.A., Inc.
`Lead Counsel
`
`Joseph A. Calvaruso (Reg. No. 28,287)
`Orrick, Herrington, & Sutcliffe LLP
`2050 Main Street, Suite 1110
`Irvine, CA 92614-8255
`Telephone: 212-506-5140
`Facsimile: 949-567-6710
`ipprosecution@orrick.com
`jcalvaruso@orrick.com
`
`
`
`12
`
`
`Axis Communications AB
`Backup Counsel
`
`Kelly S. Horn (Reg. No. 70,657)
`Guang-Yu Zhu (Reg. No. 66,250)
`Finnegan, Henderson, Farabow,
`Garrett & Dunner LLP
`901 New York Avenue, NW
`Washington, DC 20001-4413
`Telephone: 202-408-43131
`Facsimile: 202-408-4400
`kelly.horn@finnegan.com
`guang-yu.zhu@finnegan.com
`
`
`Canon Inc. and Canon U.S.A., Inc.
`Back-Up Counsel
`
`Richard F. Martinelli (Reg. No. 52,003)
`Orrick, Herrington, & Sutcliffe LLP
`2050 Main Street, Suite 1110
`Irvine, CA 92614-8255
`Telephone: 212-506-5140
`Facsimile: 949-567-6710
`ipprosecution@orrick.com
`rmartinelli@orrick.com
`
`
`
`Patent Owner’s Opp. to Petitioners’ Mot. for Auth. to Compel Test. and/or Docs.
`IPR2019-00314
`
`
`
`
`
`
` /s/ Eugene Goryunov
`
`Eugene Goryunov (Reg. No. 61,579)
`KIRKLAND & ELLIS LLP
`300 North LaSalle
`Chicago, IL 60654
`Telephone: 312-862-2000
`Facsimile: 312-862-2200
`eugene.goryunov@kirkland.com
`
`Akshay S. Deoras (pro hac vice)
`KIRKLAND & ELLIS LLP
`555 California Street
`San Francisco, CA 94104
`Telephone: 415-439-1400
`Facsimile: 415-439-1500
`akshay.deoras@kirkland.com
`
`Michael W. De Vries (pro hac vice)
`KIRKLAND & ELLIS LLP
`333 South Hope Street
`Los Angeles, CA 90071
`Telephone: 213-680-8400
`Facsimile: 213-680-8500
`michael.devries@kirkland.com
`
`
`Dated: August 23, 2019
`
`Reza Dokhanchy (Reg. No. 62,795)
`KIRKLAND & ELLIS LLP
`555 California Street
`San Francisco, CA 94104
`Telephone: 415-439-1400
`Facsimile: 415-439-1500
`reza.dokhanchy@kirkland.com
`
`Adam R. Alper (pro hac vice)
`KIRKLAND & ELLIS LLP
`555 California Street
`San Francisco, CA 94104
`Telephone: 415-439-1400
`Facsimile: 415-439-1500
`adam.alper@kirkland.com
`
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`13
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