Petitioner’s Request for Rehearing
`IPR2020-00420
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________
`
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`ERICSSON 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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`__________________
`
`
`IPR Case No. IPR2020-00420
`U.S. Patent No. 6,868,079
`
`__________________
`
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`PETITIONER’S REQUEST FOR REHEARING PURSUANT TO
`37 C.F.R § 42.71(d)
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`
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`IPR2020-00420
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`
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________
`
`
`ERICSSON INC.,
`
`Petitioner
`
`v.
`
`UNILOC 2017 LLC,
`
`Patent Owner
`
`__________________
`
`
`IPR Case No. IPR2020-00420
`U.S. Patent No. 6,868,079
`
`__________________
`
`
`PETITIONER’S REQUEST FOR REHEARING PURSUANT TO
`37 C.F.R § 42.71(d)
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`Petitioner’s Request for Rehearing
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`IPR2020-00420
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`Table of Contents
`INTRODUCTION ............................................................................................... 1
`I.
`II. ARGUMENT .................................................................................................... 1
`A. The Board mistakenly determined that claim 17 is the only asserted claim in
`district court. ........................................................................................................... 2
`B. The Board did not account for the relative timing of Patent Owner’s district
`court assertions on the GP factors. ......................................................................... 7
`C. The Board improperly disregarded that Petitioner was not previously aware
`of Alamouti and Ling in the analysis of GP factors two and four. ......................11
`D. Good cause exists for admitting public district court filing Exhibit 1042 into
`the record. .............................................................................................................12
`III. CONCLUSION ..............................................................................................14
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`ii
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`Petitioner’s Request for Rehearing
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`IPR2020-00420
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`I.
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`INTRODUCTION
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`Pursuant to 37 C.F.R. § 42.71(d), Petitioner, Ericsson Inc. (“Petitioner” or
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`“Ericsson”), respectfully requests rehearing of the Board’s Decision Denying
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`Institution, Paper 7 (June 18, 2020) (“Decision”), which discretionarily denies
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`Ericsson’s Petition for Inter Partes Review.
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`Patent Owner did not dispute that it asserts claims 1–5, 7 and 17 in the
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`related district court litigation as set forth in the Petition. Even though the identity
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`of the asserted claims was not in dispute, the Board sua sponte reviewed select
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`district court pleadings and arrived at the incorrect conclusion that claims 1–5 and
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`7 are not asserted. Because the Board’s decision rests on a factual
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`misunderstanding of which claims are asserted in district court litigation, and
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`additionally because the Board did not properly account for the relative timing of
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`Patent Owner’s lawsuits and did not apply General Plastic factors 2 and 4
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`correctly, Ericsson respectfully requests that the Board reverse its decision and
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`institute review.
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`II. ARGUMENT
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`Ericsson respectfully requests reconsideration of the Board’s decision to
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`deny Ericsson’s petition, which the Board based on the existence of two other
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`instituted IPR proceedings: IPR2019-00510 (“IPR510”) (filed by Apple Inc., LG
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`Electronics Inc., and Samsung Electronics Co., Ltd.); and IPR2020-00038
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`1
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`Petitioner’s Request for Rehearing
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`IPR2020-00420
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`(“IPR038”) (filed by Motorola Mobility LLC). First, the Board’s decision
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`misunderstood which claims are asserted in litigation. Second, the Board should
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`have taken into account that the IPRs filed against the ’079 Patent are staggered in
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`time as a foreseeable result of Patent Owner’s staggered district court assertions
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`against the various entities. Third, the Board applied an incorrect legal standard—
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`one contrary to Board precedent—in analyzing General Plastic factors 2 and 4. See
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`General Plastic Indus. Co., Ltd. v. Canon Kabushiki Kaisha, IPR2016-01357,
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`Paper 19 at 16 (PTAB Sept. 6, 2017) (precedential as to § II.B.4.i) (“General
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`Plastic” or “GP”).
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`Because the factual findings in the Decision are not supported by substantial
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`evidence, and because the Decision is based on an erroneous interpretation of law
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`and reflects an unreasonable judgment in weighing relevant factors, Ericsson
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`respectfully submits that the Decision reflects an abuse of discretion. See Huawei
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`Device Co., Ltd. v. Optis Cellular Technology, LLC, IPR2018-00816, Paper 19 at
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`2–3 (PTAB Jan. 8, 2019) (precedential).
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`A. The Board mistakenly determined that claim 17 is the only asserted
`claim in district court.
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`The Board denied institution based on its incorrect determination that
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`Petitioner’s representation that challenged claims 1–5 and 7 are asserted in district
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`court is “refuted by what we find in the public records.” Decision at 16. In making
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`that factual determination, the Board mistakenly assumed that the Patent Owner
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`2
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`Petitioner’s Request for Rehearing
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`IPR2020-00420
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`was limited to asserting only those claims that were explicitly enumerated in the
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`Complaint (Ex. 3001). Id. at 15. Furthermore, despite consideration of the district
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`court Docket Report (Ex. 3002), the Board overlooked other public records on the
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`Docket Report listing the claims asserted against intervenor-defendant Ericsson,
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`particularly the Order staying the case pending the outcome of related IPRs. See
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`Ex. 3002, Docket Entry 47; see also related motion at Docket Entry 451). For
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`example, the Court’s Order staying the case reiterates a joint stipulation of the
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`parties, stating: “The asserted claims of the ’079 patent are claims 1, 2, 3, 4, 5, 7
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`and 17.” Ex. 1042 at 1–2 (¶ 3). Thus, Petitioner respectfully submits that public
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`documents on the district court Docket Report confirm Petitioner’s original
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`statement (see Pet. at 71, n. 2) that claims 1–5 and 7 (and claim 17) are asserted
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`against its products in district court litigation.
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`The Board correctly recognizes that Patent Owner asserts the ʼ079 Patent
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`against AT&T entities and that Patent Owner’s Complaint in Uniloc 2017 LLC v.
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`AT&T Services, Inc., AT&T Mobility LLC, 2:19-cv-00102-JRG (E.D. Tex.)
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`specifically alleges infringement of claim 17. Decision at 15 (citing Ex. 3001). The
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`Board erred, however, in its conclusion that, based on the Complaint, “only []
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`1 See also Docket Entry 32, Motion to Intervene by Ericsson Inc., at 5, 7-9
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`(explaining Ericsson’s duty to indemnify AT&T).
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`3
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`Petitioner’s Request for Rehearing
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`IPR2020-00420
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`claim 17 was asserted by Patent Owner.” Id. To be clear, the Complaint states that
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`“at least claim 17” is asserted. Ex. 3001, ¶¶ 47–50 (using this open-ended phrasing
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`on four occasions in the Complaint). As explained further below, this format for
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`pleading infringement—identifying one representative claim per patent and stating
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`that “at least” that claim is infringed—is routine in district court litigation.
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`Patent owners are typically not required to list in a complaint every claim of
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`a patent that will be asserted in litigation. This practice is especially clear in the
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`Eastern District of Texas, where the relevant district court action is pending.
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`Under Eastern District of Texas Local Patent Rule 3-12,3, “[n]ot later than 10 days
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`before the Initial Case Management Conference with the Court, a party claiming
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`patent infringement must serve on all parties a ‘Disclosure of Asserted Claims and
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`Infringement Contentions.’” These contentions require the patent owner to identify
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`“[e]ach claim of each patent in suit that is allegedly infringed by each opposing
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`2 The court’s Local Rules are available at:
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`http://www.txed.uscourts.gov/sites/default/files/courtdocuments/Local%20Rules%
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`20Combined%202019%20Final.pdf.
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`3 Because the infringement contentions, which identify all asserted claims, are
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`served on the defendants in litigation, not filed with the district court, the full list of
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`asserted claims typically cannot be gleaned from the district court docket.
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`4
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`Petitioner’s Request for Rehearing
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`IPR2020-00420
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`party.” Id. The significance of Local Patent Rule 3-1 in the pleading process is
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`confirmed by the opinions of Judge Gilstrap, the judge presiding over the district
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`court action involving Ericsson. See, e.g., Uniloc USA, Inc. v. Avaya Inc., No.
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`6:15-cv-1168-JRG, 2016 WL 7042236, at *3 (E.D. Tex. May 13, 2016) (Gilstrap,
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`J.) (explaining how the court’s Local Rules interact with pleading requirements
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`and noting that the plaintiff’s identification of “representative claims” among other
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`allegations was sufficient for purposes of a complaint); Motorola Mobility, Inc. v.
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`Tivo Inc., No. 5:11-cv-053-JRG, 2012 WL 12840340, at *3 (E.D. Tex. Nov. 30,
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`2012) (Gilstrap, J.) (“There is no requirement that a plaintiff specify in its
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`complaint which claims it asserts are infringed.”). In short, under the current
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`practice in the Eastern District of Texas, a plaintiff is simply not required to
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`identify all asserted claims in its complaint, rendering the Board’s reliance on
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`Exhibit 3001 incomplete and inaccurate.
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`Patent Owner did not contest Petitioner’s statement identifying the asserted
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`claims in its Patent Owner Preliminary Response. Nor would Petitioner have
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`expected Patent Owner to dispute Petitioner’s statement, given that Patent Owner’s
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`counsel agreed to and signed the Joint Motion to Stay in district court, which lists
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`as the asserted claims the same claims Petitioner identified to the Board. See Ex.
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`3002, at 10 (Dkt. 45). Accordingly, until the Board sua sponte raised this issue in
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`its Decision and added Exhibits 3001 and 3002 to the record, Petitioner had no
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`5
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`Petitioner’s Request for Rehearing
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`IPR2020-00420
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`reason to believe these undisputed facts would be questioned or that additional
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`evidence would be necessary to prove up Petitioner’s unchallenged
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`representations.
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`As the Board correctly emphasized, “[a]n objective of the AIA is to provide
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`an effective and efficient alternative to a district court litigation by considering the
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`patentability of claims that are involved in the district court litigation.” Decision at
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`15 (emphasis in original). Ericsson respectfully requests the opportunity to utilize
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`the IPR process for this very purpose—to challenge the claims that are asserted in
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`litigation, including six claims that are not at issue in any other IPR. See LG
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`Electronics, Inc. v. Bell Northern Research, LLC, IPR2020-00319, Paper 15
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`(PTAB June 23, 2020) (instituting a third-filed IPR even though all but one of the
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`challenged claims was already pending in an instituted IPR). Indeed, as another
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`Board panel recently concluded in similar circumstances, “the fact that this is an
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`unrelated Petitioner presenting some new references and non-overlapping claims
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`weighs against denying institution under § 314(a) quite heavily.” Id. at 15
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`(emphasis added).
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`Accordingly, Ericsson respectfully requests reconsideration of the institution
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`decision based on a correct understanding of which claims are asserted in
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`litigation, particularly considering anew Petitioner’s argument that “without any
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`overlapping products or relationship between [prior petitioners], Petitioner should
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`6
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`Petitioner’s Request for Rehearing
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`IPR2020-00420
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`be given its own opportunity to be heard on its arguments challenging new claims
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`not challenged in any prior Petition.” Pet. at 71.
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`B. The Board did not account for the relative timing of Patent Owner’s
`district court assertions on the GP factors.
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`The Board penalized Petitioner for filing an IPR after Motorola Mobility by
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`reasoning that General Plastic factors 2, 4, and 5 favor denying institution (and
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`that factor 3 is neutral). See Decision at 10–13. The Board’s analysis, however,
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`overlooked the fact that the lawsuit involving Motorola Mobility (the petitioner in
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`IPR038) commenced over four months prior to the lawsuit involving Ericsson,
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`rendering the timing of Ericsson’s IPR as a natural and foreseeable consequence of
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`Patent Owner’s litigation strategy.
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`GP factors 2–5 relate generally to the reasons for the relative timing of
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`multiple IPR petitions. General Plastic Indus. Co., Ltd., IPR2016-01357, Paper 19
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`at 16. The table below summarizes the dates Uniloc filed complaints against the
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`petitioner entities involved in each of the three IPRs relevant to the Decision, as
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`well as the corresponding dates of the IPR filings, shedding light on the
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`reasonableness of the relative timing of Ericsson’s IPR.
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`7
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`Petitioner’s Request for Rehearing
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`IPR2020-00420
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`Date of
`Original
`Complaint
`Feb. 22, 2018
`
`Related District
`Court
`Case No.
`1:18-cv-00158
`(W.D.Tex.)
`(later transferred
`to N.D.Cal.)
`2:18-cv-00042
`(E.D.Tex.)
`3:18-cv-00557
`(N.D.Tex.)
`Nov. 20, 2018 1:18-cv-01841
`(D. Del.)
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`Feb. 23, 2018
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`Mar. 9, 2018
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`Date of
`IPR Filing
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`Jan. 10, 2019
`
`Claims
`Challenged in
`IPR
`17, 18
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`Jan. 10, 2019
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`Jan. 10, 2019
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`17, 18
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`17, 18
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`Oct. 11, 2019
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`17
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`Jan. 17, 2020
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`1-5, 7, 17
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`Petitioner
`Entity
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`Apple
`(IPR510)
`
`Samsung
`(IPR510)
`LG
`(IPR510)
`Motorola
`Mobility
`(IPR038)
`Ericsson
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`Mar. 26, 2019 2:19-cv-00102
`(E.D.Tex.)
`
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`See Paper 4 at 2 (listing case filing dates); Ex. 3001 (showing filing date of 2:19-
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`cv-102).
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`As illustrated in the table, Patent Owner sued Motorola Mobility (the
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`petitioner in IPR038) four months prior to filing the lawsuit involving Ericsson’s
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`products. Yet the Board faulted Ericsson for purportedly taking too long to file its
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`Petition challenging claims 1–5, 7 and 17, for example, by stating that “Petitioner
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`has not provided an adequate explanation” for why it could not have filed its
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`petition earlier. Decision at 12.
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`The timing of Ericsson’s Petition was a natural and foreseeable result of
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`Patent Owner’s decision to file lawsuits staggered in time against various unrelated
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`defendants. See Microsoft Corp. v. Uniloc 2017, LLC, IPR2019-01252, Paper 7 at
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`9–10 (PTAB Dec. 20, 2019) (explaining with respect to GP factors 3–5 that “the
`8
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`Petitioner’s Request for Rehearing
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`IPR2020-00420
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`length of time between the [earlier petition] and the Petition in this case was the
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`result of the timing of Patent Owner’s infringement action, not an attempt by
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`Petitioner to gain an unfair advantage”). Specifically, it was entirely foreseeable
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`that an additional IPR would be filed once Patent Owner chose to assert to claims
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`1–5 and 7, which have not been challenged in any other IPR4.
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`In analyzing GP factor 3, the Board correctly recognizes that the lawsuits
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`involving Petitioner entities of IPR510 were filed well before March 26, 2019, the
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`date of the original complaint in the lawsuit involving Ericsson. See Decision at 11
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`(citing IPR2020-00038, Paper 9 at 8 and explaining that Petitioner entities of
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`IPR510 were sued around eight months prior to when Petitioner of IPR038 was
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`sued). The Board properly took that timing into account in its analysis of GP factor
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`3. Petitioner respectfully submits that the Board should have applied a similar
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`4 Although challenges to claim 17 are currently pending in IPR510 and IPR038,
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`either of those existing IPRs could settle at any time, leaving claim 17 entirely
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`unchallenged. For example, had Ericsson waited to see if IPR038 instituted before
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`filing its IPR addressing claims 1-5 and 7, the parties in IPR038 could have settled
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`before institution (and Ericsson could have been faulted for waiting to see Patent
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`Owner’s Preliminary Response), leaving Ericsson potentially time-barred from
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`filing any IPR.
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`9
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`Petitioner’s Request for Rehearing
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`IPR2020-00420
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`analysis to the relative timing of the lawsuit involving the Petitioner entity of
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`IPR038.
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`The Board approved of a similar argument when raised by Motorola in
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`IPR038. Specifically, the Board in analyzing GP factor 5 considered and found
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`reasonable Motorola’s argument that the nine-month delay between the filing of
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`IPR510 and IPR038 was excusable because Uniloc filed suit against Motorola nine
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`months after it sued the IPR510 petitioners. See IPR038, Paper 9 at 9 (PTAB Apr.
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`13, 2020). Although the Board states that “the near ten-month gap between March
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`26, 2019, and January 17, 2020, has not been adequately explained,” see Decision
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`at 13 (referring to the date Uniloc filed the suit involving Ericsson), the two IPRs
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`already instituted by the Board were also filed around 10 months after the
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`petitioners in those cases were sued by Uniloc, as shown in the table above.
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`Ericsson simply asks that the Board reweigh its analysis in this case to account for
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`the same reality that exists here—Ericsson filed its Petition three months after the
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`IPR038 petition consistent with Patent Owner filing the suit involving Ericsson
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`four months after it sued Motorola (the petitioner in IPR038).
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`In sum, given that Patent Owner filed the lawsuit involving Ericsson over
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`one year after it filed lawsuits against the IPR510 petitioners and over four months
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`after the lawsuit involving the IPR038 petitioner, the timing considerations in GP
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`factors 2–5 weigh in favor of institution.
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`10
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`Petitioner’s Request for Rehearing
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`IPR2020-00420
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`C. The Board improperly disregarded that Petitioner was not previously
`aware of Alamouti and Ling in the analysis of GP factors two and four.
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`In addressing GP factors 2 and 4, the Board applied a new standard
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`regarding a petitioner’s knowledge of prior art references that is inconsistent with
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`the express language of these GP factors by focusing on a petitioner’s knowledge
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`of technical subject matter rather than knowledge of specific prior art references.
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`Specifically, as to GP factor 2, the Board faulted Petitioner for “not contend[ing]
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`that it knew of no reference that discloses what Alamouti discloses and what Ling
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`discloses.” Decision at 10 (emphasis added). As to factor 4, the Board again
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`faulted Petitioner for “not represent[ing] that it was lack of knowledge of the
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`subject matter described in Alamouti and Ling, wherever disclosed, that
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`prevented earlier filing of the Petition.” Id. at 11 (emphasis added). The Board took
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`this reasoning even further, suggesting that Ericsson should have “contend[ed] that
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`diversity transmission and/or reception originated with Alamouti or was not
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`otherwise disclosed in any prior art known to Petitioner.” Id.
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`Contrary to the Board’s analysis, the focus of GP factors 2 and 4 is on “the
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`prior art asserted in the [later-filed] petition.” General Plastic, IPR2016-01357,
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`Paper 19 at 16. Knowledge of technical subject matter—even knowledge of other
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`references disclosing that subject matter—does not address the question of whether
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`and when a petitioner knew of the prior art references it relies on in a petition.
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`11
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`Petitioner’s Request for Rehearing
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`IPR2020-00420
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`As explained in Ericsson’s Petition, see Pet. at 71–73, Ericsson learned of
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`the Alamouti reference when IPR038 was filed, and Ericsson did not discover the
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`Ling reference until even later. Accordingly, Ericsson respectfully requests that the
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`Board reconsider its analysis with respect to GP factors 2 and 4 to analyze those
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`factors under the proper legal standard. Under a correct analysis, GP factors 2 and
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`4 weigh against denial of institution.
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`D. Good cause exists for admitting public district court filing Exhibit 1042
`into the record.
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`For rehearing requests, “evidence not already of record at the time of the
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`decision will not be admitted absent a showing of good cause.” Huawei Device
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`Co., Ltd., IPR2018-00816, Paper 19 at 3-4 (internal citations omitted). A party may
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`argue good cause in the rehearing request. Id. at 4.
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`Good cause exists for admitting Exhibit 1042, which is a copy of the district
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`court’s Order Granting Motion to Stay through Completion of the Instituted IPR
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`Proceedings, listed as document 47 in the district court docket added to the record
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`by the Board as Ex. 3002. The Board did not include the Order Granting Motion to
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`Stay through Completion of the Instituted IPR Proceedings as a document relevant
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`to the sua sponte consideration of the claims asserted in the district court litigation.
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`Exhibit 1042 is being submitted for the convenience of the Board, even though the
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`document is available to the public. It is respectfully submitted that Exhibit 1042
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`contradicts the Board’s determination that “we independently do not find claims 1-
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`12
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`Petitioner’s Request for Rehearing
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`IPR2020-00420
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`5 and 7 to be involved in the district court case in which Petitioner intervened.”
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`Decision at 15.
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`There was no need for Ericsson to have submitted this exhibit earlier
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`because Ericsson’s representation as to which claims are asserted was not being
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`disputed by Patent Owner. However, because the Board sua sponte disputed
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`Ericsson’s statement regarding which claims are asserted, admitted and
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`misinterpreted evidence from the district court docket without first notifying the
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`parties (Exs. 3001–3002), and decided the issue against Ericsson, all without
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`Ericsson having notice and an opportunity to provide this evidence, good cause
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`exists to admit Exhibit 1042 in response. Moreover, because Exhibits 3001–3002
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`were admitted and relied upon by the Board without notice to Petitioner, Petitioner
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`is entitled to be heard as to that evidence, including by allowing Ericsson to submit
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`evidence in response. See Fed. R. Evid. 201(e) (“If the court takes judicial notice
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`before notifying a party, the party, on request, is still entitled to be heard.”); see
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`also 37 C.F.R. § 42.62(c) (equating judicial notice and official notice).
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`Additionally, because Exhibit 1042 is a publicly available court document
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`with an unambiguous joint stipulation of the parties as to the asserted claims of the
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`’079 Patent that is not subject to reasonable dispute, the Board may take official
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`notice of the statement of asserted claims. See 37 C.F.R. § 42.62(a),(c). The Board
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`13
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`Petitioner’s Request for Rehearing
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`IPR2020-00420
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`may take notice of such facts “at any stage of the proceeding.” See Fed. R. Evid.
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`201(d).
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`For these reasons, good cause exists to admit Exhibit 1042 into the record.
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`III. CONCLUSION
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`For the foregoing reasons, Petitioner respectfully requests that the Board
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`reverse its decision and institute an inter partes review.
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`/J. Andrew Lowes/
`J. Andrew Lowes
`Counsel for Petitioner
`Registration No. 40,706
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`14
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`Petitioner’s Request for Rehearing
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`IPR2020-00420
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`CERTIFICATE OF SERVICE
`
`The undersigned certifies, in accordance with 37 C.F.R. § 42.6(e), that
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`service was made on the Patent Owner as detailed below:
`
`Date of service July 14, 2020
`
`Manner of service Electronic Mail: ryan@etheridgelaw.com;
`brett@etheridgelaw.com; jim@etheridgelaw.com;
`brian@etheridgelaw.com; jeff@etheridgelaw.com
`
`Documents served Petitioner’s Request for Rehearing
`
`Ryan Loveless
`Brett Mangrum
`James Ethridge
`Brian Koide
`Jeffrey Huang
`Etheridge Law Group
`2600 E. Southlake Blvd., Ste. 120-324
`Southlake, TX 76092
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`Persons served
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`/J. Andrew Lowes/
`J. Andrew Lowes
`Counsel for Patent Owner
`Registration No. 40,706
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