UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`SAMSUNG ELECTRONICS AMERICA, INC.
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`Petitioner
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`v.
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`UNILOC 2017 LLC
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`Patent Owner
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`IPR2019-01219
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`PATENT 6,836,654
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`PATENT OWNER PRELIMINARY RESPONSE TO PETITION
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`PURSUANT TO 37 C.F.R. §42.107(a)
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`SAMSUNG ELECTRONICS AMERICA, INC.
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`Petitioner
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`v.
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`UNILOC 2017 LLC
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`Patent Owner
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`IPR2019-01219
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`PATENT 6,836,654
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`PATENT OWNER PRELIMINARY RESPONSE TO PETITION
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`PURSUANT TO 37 C.F.R. §42.107(a)
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`IPR2019-01219
`U.S. Patent 6,836,654
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`Table of Contents
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`
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`I.
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`II.
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`INTRODUCTION .................................................................................... 1
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`THE ’654 PATENT .................................................................................. 1
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`III.
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`RELATED PROCEEDINGS .................................................................... 3
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`IV.
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`V.
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`VI.
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`GIVEN THE TRIAL SCHEDULE IN PARALLEL
`LITIGATION, AND MULTIPLE PETITIONS FILED BY
`PETITIONER ON THE ’654 PATENT, THE BOARD
`SHOULD EXERCISE DISCRETION UNDER 35 U.S.C.
`§ 314(A) AND NHK SPRING TO DENY INSTITUTION ..................... 3
`
`THE PETITION DOES NOT ESTABLISH PUBLIC
`ACCESSIBILITY OF NOKIA AS A PRINTED
`PUBLICATION PRIOR TO THE ’654 PATENT’S
`PRIORITY DATE (GROUND 1) ............................................................. 7
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`THE PETITION SHOULD BE DENIED UNDER THE
`BOARD’S DISCRETION DUE TO THE NUMBER OF
`CLAIMS AND GROUNDS ................................................................... 10
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`VII.
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`CONCLUSION ....................................................................................... 12
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`ii
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`IPR2019-01219
`U.S. Patent 6,836,654
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`No.
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`LIST OF EXHIBITS
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`
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`Description
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`2001 Uniloc 2017 LLC v. Samsung Elecs. Am., Inc., No. 2:18-
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`00508, Docket Control Order, D.I. 20 (E.D. Tex.)
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`2002 Exhibit A-1 to Samsung Invalidity Contentions, Uniloc 2017 LLC
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`v. Samsung Elecs. Am., Inc., No. 2:18-00508 (E.D. Tex.)
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`2003 Exhibit B to Samsung Invalidity Contentions, Uniloc 2017 LLC v.
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`Samsung Elecs. Am., Inc., No. 2:18-00508 (E.D. Tex.)
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`iii
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`IPR2019-01219
`U.S. Patent 6,836,654
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`I.
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`INTRODUCTION
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`Uniloc 2017 LLC (“Uniloc” or “Patent Owner”) submits this Preliminary
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`Response to Petition IPR2019-01219 for Inter Partes Review (“Pet.” or “Petition”)
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`of United States Patent No. 6,836,654 (“the ’654 patent” or “EX1001”) filed by
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`Samsung Electronics America, Inc. (“Petitioner”). The instant Petition is defective
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`for at least the reasons set forth herein.
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`II. THE ’654 PATENT
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`The ’654 patent is titled “Anti-theft protection for a radiotelephony device.”
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`The ʼ654 patent issued December 28, 2004, from U.S. Patent Application No.
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`09/739,507 filed December 18, 2000, claiming priority to French application 99-
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`16136, filed December 21, 1999.
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`Figure 3 of the ’654 patent, reproduced below, is a flow chart depicting an
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`example embodiment.
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`1
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`IPR2019-01219
`U.S. Patent 6,836,654
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`The text accompanying Figure 3 describes operation from box K1 at the top
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`of the figure, in which the device is in a state of availability, through various blocking
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`states (K5, K11, K30) and decisional nodes related to these blocking states. See
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`2
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`IPR2019-01219
`U.S. Patent 6,836,654
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`EX1001, 2:61–4:6.
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`III. RELATED PROCEEDINGS
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`The following proceedings are currently pending cases concerning U.S. Pat.
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`No. 6,836,654 (EX1001).
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`Case Name
`Uniloc 2017 LLC et al v. Google
`LLC
`Uniloc 2017 LLC v. Samsung
`Electronics America, Inc. et al
`Uniloc 2017 LLC v. Motorola
`Mobility, LLC
`Uniloc 2017 LLC v. HTC America,
`Inc.
`Uniloc USA, Inc. et al v. Apple Inc.
`Uniloc 2017 LLC v. Microsoft
`Corporation
`Samsung Electronics America, Inc.
`v. Uniloc 2017 LLC
`Samsung Electronics America, Inc.
`v. Uniloc 2017 LLC
`Microsoft Corporation v. Uniloc
`2017 LLC
`Microsoft Corporation v. Uniloc
`2017 LLC
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`
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`Case Number
`2-18-cv-00493
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`Court
`TXED
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`Filing Date
`11/17/2018
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`2-18-cv-00508
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`TXED
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`11/17/2018
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`1-18-cv-01844
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`DED
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`11/20/2018
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`2-18-cv-01732 WAWD
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`11/30/2018
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`3-19-cv-01697
`8-19-cv-00781
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`CAND
`CACD
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`4/2/2019
`4/29/2019
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`IPR2019-01218
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`PTAB
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`6/19/2019
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`IPR2019-01219
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`PTAB
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`6/19/2019
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`IPR2019-01470
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`PTAB
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`8/9/2019
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`IPR2019-01471
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`PTAB
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`8/9/2019
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`IV. GIVEN THE TRIAL SCHEDULE IN PARALLEL LITIGATION,
`AND MULTIPLE PETITIONS FILED BY PETITIONER ON THE
`’654 PATENT, THE BOARD SHOULD EXERCISE DISCRETION
`UNDER 35 U.S.C. § 314(A) AND NHK SPRING TO DENY
`INSTITUTION
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`Instituting a trial under the facts and circumstances of this case would be an
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`inefficient use of Board resources. As Petitioner acknowledges, jury selection is set
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`3
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`IPR2019-01219
`U.S. Patent 6,836,654
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`to begin in the parallel litigation involving Petitioner on July 6, 2020, which is
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`approximately six months prior to any expected decision from the Board in this case
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`if trial were instituted. Pet. 75; see Uniloc 2017 LLC v. Samsung Elecs. Am., Inc.,
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`No. 2:18-00508, D.I. 20 (E.D. Tex.) (submitted for convenience of the Board as
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`Exhibit 2001). Petitioner asserts that it filed this Petition “promptly,” despite a delay
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`of eight months from the re-filing of the district court case, and inexplicably asserts
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`that “the section 314(a) consideration regarding parallel litigation in NHK Spring
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`Co., Ltd. v. Intri-plex Technologies, IPR2018-00752, Paper No. 8 at 20 (P.T.A.B.
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`Sept. 12, 2018), is wholly inapplicable here.” Pet. 75. To the contrary, the Board’s
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`precedential decision in NHK Spring is on point as to discretionary denial under
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`§ 314(a) based on the status of parallel litigation. Denial of institution on this basis
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`is respectfully requested.
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`In NHK Spring, expert discovery was set to close on November 1, 2018,
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`approximately two months from the date of the institution decision of September 12,
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`2018. NHK Spring, Paper No. 8, 20. Trial was set to begin on March 25, 2019, just
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`over six months from the date of the institution decision. Id. Thus, the Board noted
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`that trial before it on the same asserted prior art would not conclude until September
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`2019, which was six months after the scheduled trial date before the district court.
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`Id. The Board determined that “[i]nstitution of an inter partes review under these
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`circumstances would not be consistent with ‘an objective of the AIA . . . to provide
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`an effective and efficient alternative to district court litigation.’” Id. (quoting
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`General Plastic Indus. Co., Ltd. v. Canon Kabushiki Kaisha, Case IPR2016-01357
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`4
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`IPR2019-01219
`U.S. Patent 6,836,654
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`(Paper 19) (PTAB Sept. 6, 2017) (precedential as to § II.B.4.i)). The Board thus
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`found that the advanced state of the district court proceeding weighed in favor of
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`denying the Petition under § 314(a). Id. Although NHK Spring also involved factors
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`under § 325(d), and considered the advanced state of the district court litigation as
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`an additional factor, NHK Spring does not indicate that the state of district court
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`litigation can only be considered with other specific factors, rather than as part of a
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`balanced assessment of all relevant circumstances in the case. See also Thermo
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`Fisher Scientific, Inc. v. Regents of Univ. of Cal., IPR2018-01370, slip op. at 25–27
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`(Paper 11) (PTAB Feb. 7, 2019) (determining that “the advanced stage of the
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`pending district court proceeding, along with the similarities involved in that
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`proceeding and the Petition, warrant additionally denying the Petition under
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`§ 314(a)”).
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`Here, a decision on institution is not expected until January 2020, which
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`means a trial before the Board would not conclude until January 2021. As Petitioner
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`acknowledges, Pet. 75, jury selection at the start of trial before the district court is
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`set for July 6, 2020, which is only six months after an anticipated decision on
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`institution and six months prior to conclusion of trial before the Board if one were
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`instituted, as in NHK Spring. And, as in NHK Spring, the same grounds proposed
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`in the Petition are included in Petitioner’s invalidity contentions in the district court.
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`See EX2002 (Exhibit A-1 to Petitioner’s invalidity contentions in Uniloc 2017 LLC
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`v. Samsung Elecs. Am., Inc., No. 2:18-00508 (E.D. Tex.); EX2003 (Exhibit B to
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`Petitioner’s invalidity contentions). Expert discovery will close March 30, 2020,
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`5
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`IPR2019-01219
`U.S. Patent 6,836,654
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`which is less than three months from an expected decision on institution in this
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`proceeding. EX2001. Although the district court has yet to construe the claims, a
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`claim construction hearing is set for December 17, 2019, prior to the anticipated date
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`of a decision on institution in this proceeding. Id.1 Samsung’s decision to wait eight
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`months from the filing of the infringement lawsuit to file its Petition, even after
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`having earlier notice of the patent as asserted in a prior suit,2 has directly and
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`foreseeably resulted in the district court proceeding reaching this advanced stage
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`relative to this proceeding. As in NHK Spring, “[i]nstitution of an inter partes
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`review under these circumstances would not be consistent with ‘an objective of the
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`AIA . . . to provide an effective and efficient alternative to district court litigation.’”
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`NHK Spring, Paper No. 8, 20. Patent Owner, therefore, requests that the Board
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`exercise its discretion not to institute trial under the circumstances of this case.
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`An additional factor weighing in favor of denying the Petition is Petitioner’s
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`filing of two petitions on the ’654 patent at the same time, which places a substantial
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` 1
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` In light of the revised standard for claim construction in IPR proceedings, the
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`district court will construe the claims applying the same claim construction
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`standard as the Board.
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`2 Uniloc USA, Inc. et al v. Samsung Electronics America, Inc. et al, Case 2-18-cv-
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`00309 (E.D. Tex.) (filed July 23, 2018).
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`6
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`IPR2019-01219
`U.S. Patent 6,836,654
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`and unnecessary burden on the Board and the Patent Owner, and raises fairness,
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`timing, and efficiency concerns. On the same day, Petitioner filed petitions on the
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`’654 patent asserting unpatentability of (1) claims 1–9 based on various grounds
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`including Nokia, Alos, Matsukida, Miller, and one additional reference (Kemppi),
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`in IPR2019-01218, and (2) claims 10–20 based on similar grounds including Nokia,
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`Alos, Matsukida, and Miller, in IPR2019-01219. As the Board recognized in the
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`July 2019 Trial Practice Guide Update:
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`Based on the Board’s prior experience, one petition should be
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`sufficient to challenge the claims of a patent in most situations. Two or
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`more petitions filed against the same patent at or about the same time
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`(e.g., before the first preliminary response by the patent owner) may
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`place a substantial and unnecessary burden on the Board and the patent
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`owner and could raise fairness, timing, and efficiency concerns. See 35
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`U.S.C. § 316(b). In addition, multiple petitions by a petitioner are not
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`necessary in the vast majority of cases. To date, a substantial majority
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`of patents have been challenged with a single petition.
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` Trial Practice Guide Update, 26 (July 2019). This is not a “rare” case in which
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`“more than one petition may be necessary, including, for example, when the patent
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`owner has asserted a large number of claims in litigation or when there is a dispute
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`about priority date requiring arguments under multiple prior art references.” Id.
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`V. THE PETITION DOES NOT ESTABLISH PUBLIC ACCESSIBILITY
`OF NOKIA AS A PRINTED PUBLICATION PRIOR TO THE ’654
`PATENT’S PRIORITY DATE (GROUND 1)
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`The alleged evidence relied on by the Petition to show that Nokia (EX1004)
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`7
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`IPR2019-01219
`U.S. Patent 6,836,654
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`is a printed publication falls far short of proving the allegation. The Petition relies
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`on unauthenticated website printouts, use in prior cases, and an unsworn declaration
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`from another case lacking support for public accessibility of the exhibit offered in
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`this case. See Pet. 73–74. In addition, the copyright or print dates on certain of the
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`exhibits are hearsay and also do not alone establish public accessibility.
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`First, none of the websites relied on by the Petition are authenticated or even
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`accompanied by a declaration purporting to authenticate them. Exhibits 1010, 1011,
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`1012, 1013, and 1014 appear to be printouts from the “Wayback Machine” website.
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`There is no declaration authenticating the printouts, let alone of the underlying
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`websites themselves. “When offering a printout of a webpage into evidence to prove
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`the website’s contents, the proponent of the evidence must authenticate the
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`information from the website itself, not merely the printout.” Neste Oil Oyj v. Reg
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`Synthetic Fuels, LLC, IPR2013-00578, Paper No. 53, at 4 (PTAB Mar. 12, 2015)
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`(excluding printouts from Internet Archive’s “Wayback Machine,” even though
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`accompanied by testimony that the exhibits were true and correct printouts of the
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`identified webpages) (citing Victaulic Co. v. Tieman, 499 F.3d 227, 236 (3d Cir.
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`2007), as amended (Nov. 20, 2007) (citing United States v. Jackson, 208 F.3d 633,
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`638 (7th Cir. 2000))). “For this reason, the Board has required that ‘[t]o authenticate
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`printouts from a website, the party proffering the evidence must produce some
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`statement or affidavit from someone with knowledge of the website . . . for example
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`a web master or someone else with personal knowledge would be sufficient.’” Id.
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`(quoting EMC Corp. v. Personalweb Techs., LLC, Case IPR2013-00084, slip op. 45
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`8
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`IPR2019-01219
`U.S. Patent 6,836,654
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`(PTAB May 15, 2014) (Paper 64)). Here, no testimony accompanies the website
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`printouts to authenticate them to any extent, and they should be afforded no weight.
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`Second, as to the Petition’s assertion that the Nokia Communicator Owner’s
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`manual “has been frequently cited as prior art,” Pet. 73, use in prior cases does not
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`relieve Petitioner of the burden of proving that the exhibit it proffers in this case
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`qualifies as a printed publication.
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`Finally, the unsworn declaration of Jari Toivanen (EX1017) from another
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`case, also does not prove public accessibility. The unsworn declaration does not
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`meet the required form of evidence in this proceeding. See FedEx Corp. v. Ronald
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`A. Katz Tech. Licensing, L.P., Case CBM2015-00053, Paper No. 9, at 7–8 (PTAB
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`June 29, 2015) (giving no weight to unsworn declaration). Under 37 C.F.R. § 42.63,
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`“[e]vidence consists of affidavits, transcripts of depositions, documents, and things.”
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`“Affidavit means affidavit or declaration under § 1.68 of this chapter. A transcript
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`of an ex parte deposition or a declaration under 28 U.S.C. 1746 may be used as an
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`affidavit.” 37 C.F.R. § 42.2. Section 1.68, 37 C.F.R., sets forth requirements for a
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`declaration, including that “the declarant is on the same document, warned that
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`willful false statements and the like are punishable by fine or imprisonment, or both
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`(18 U.S.C. 1001) and may jeopardize the validity of the application or any patent
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`issuing thereon,” and that “[t]he declarant must set forth in the body of the
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`declaration that all statements made of the declarant’s own knowledge are true and
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`that all statements made on information and belief are believed to be true.” The
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`purported declaration of Mr. Toivanen contains none of the above, and is also not
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`9
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`IPR2019-01219
`U.S. Patent 6,836,654
`
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`sworn under penalty of perjury as provided for in 28 U.S.C. § 1746. Accordingly,
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`the Toivanen declaration cannot be afforded any weight.
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`Even if the Toivanen declaration were improperly afforded any weight, the
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`Petition asserts based on the declaration that “Mr. Toivanen was ‘a member of the
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`team responsible for developing the . . . Nokia 9000i Communicator’ and
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`testified that ‘Nokia publicly distributed a user’s manual for the Nokia 9000i
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`Communicator by at least October 1997.’” Pet. 74 (quoting EX1017, 1). The
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`conclusory assertion that a user’s manual was “publicly distributed” does not
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`provide any detail as to the factors affecting public accessibility of a reference
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`to qualify as a printed publication, and the Petition makes no effort to analyze
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`these factors.
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`Accordingly, the Petition fails to show that Nokia (EX1004) is a printed
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`publication, and there is no reasonable likelihood of Petitioner prevailing on any
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`ground relying on Nokia.
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`VI. THE PETITION SHOULD BE DENIED UNDER THE BOARD’S
`DISCRETION DUE TO THE NUMBER OF CLAIMS AND
`GROUNDS
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`The Petition presents two grounds for each of 11 claims. If the Board
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`determines that there is a reasonable likelihood of Petitioner prevailing with respect
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`to a small number of claims or only one ground, the Board should exercise discretion
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`not to institute review because it would not be an efficient use of the Board’s time
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`and resources.
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`As the Board explains in its informative decision Deeper, UAB v. Vexilar,
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`10
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`
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`Inc., Case IPR2018-01310, Paper 7 at 42 (Jan. 24, 2019):
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`IPR2019-01219
`U.S. Patent 6,836,654
`
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`[E]ven when a petitioner demonstrates a reasonable likelihood
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`of prevailing with respect to one or more claims, institution of review
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`remains discretionary. SAS Inst. Inc. v. Iancu, 138 S. Ct. 1348, 1356
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`(2018) (“[Section] 314(a) invests the Director with discretion on the
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`question whether to institute review . . . .” (emphasis omitted));
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`Harmonic Inc. v. Avid Tech., Inc., 815 F.3d 1356, 1367 (Fed. Cir. 2016)
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`(“[T]he PTO is permitted, but never compelled, to institute an IPR
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`proceeding.”). In exercising that discretion, we are guided by the
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`statutory requirement, in promulgating regulations for inter partes
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`review, to consider the effect of any regulations on “the efficient
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`administration of the Office [and] the ability of the Office to timely
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`complete proceedings,” 35 U.S.C. § 316(b), as well as the requirement
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`to construe our rules to “secure the just, speedy, and inexpensive
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`resolution of every proceeding,” 37 C.F.R. § 42.1(b). Office guidance,
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`issued June 5, 2018, also explains that the Board may consider the
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`number of claims and grounds that meet the reasonable likelihood
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`standard when deciding whether to institute inter partes review under
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`35 U.S.C. § 314(a). SAS Q&A’s, Part D, Effect of SAS on Future
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`Challenges that Could Be Denied for Statutory Reasons (June 5, 2018),
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`available
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`at
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`https://www.uspto.gov/sites/default/files/documents/
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`sas_qas_20180605.pdf (“[T]he panel will evaluate the challenges and
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`determine whether, in the interests of efficient administration of the
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`Office and integrity of the patent system (see 35 USC § 316(b)), the
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`entire petition should be denied under 35 USC § 314(a).”).
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`11
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`IPR2019-01219
`U.S. Patent 6,836,654
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`VII. CONCLUSION
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`For at least the reasons set forth above, Uniloc respectfully requests that the
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`Board deny all challenges in the instant Petition. Should the Board decide to institute
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`trial despite the arguments presented above, Patent Owner reserves the right to
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`challenge the Petition on all grounds.3
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`Date: October 11, 2019
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`Respectfully submitted,
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`By: /Brett A. Mangrum/
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`Brett A. Mangrum; Reg. No. 64,783
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`Attorney for Patent Owner
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` 3
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` Patent Owner does not concede, and specifically denies, that there is any legitimacy
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`to any arguments in the instant Petition that are not specifically addressed herein.
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`12
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`IPR2019-01219
`U.S. Patent 6,836,654
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`CERTIFICATE OF COMPLIANCE
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`
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`Pursuant to 37 C.F.R. § 42.24(d), the undersigned certifies that the foregoing
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`Preliminary Response to Petition complies with the type-volume limitation of 37
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`C.F.R. § 42.24(b)(1) because it contains fewer than the limit of 14,000 words, as
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`determined by the word-processing program used to prepare the brief, excluding
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`the parts of the brief exempted by 37 C.F.R. § 42.24(a)(1).
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`Date: October 11, 2019
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`Respectfully submitted,
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`By: /Brett A. Mangrum/
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`Brett A. Mangrum; Reg. No. 64,783
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`Attorney for Patent Owner
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`i
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`IPR2019-01219
`U.S. Patent 6,836,654
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. §§ 42.6(e), the undersigned certifies that an electronic
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`copy of the foregoing Patent Owner Preliminary Response was served, along with any
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`accompanying exhibits, via the PTAB E2E system and/or email to Petitioner’s
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`counsel at the following addresses identified in the Petition’s consent to electronic
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`service:
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`Lead Counsel:
`Naveen Modi (Reg. No. 46,224)
`PH-Samsung-Uniloc-IPR@paulhastings.com
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`Backup Counsel:
`Joseph E. Palys (Reg. No. 46,508)
`Phillip W. Citroën (Reg. No. 66,541)
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`Date: October 11, 2019
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`Respectfully submitted,
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`By: /Brett A. Mangrum/
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`Brett A. Mangrum; Reg. No. 64,783
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`Attorney for Patent Owner
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`ii
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