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`Case No. IPR2020-01265
`Patent No. 7,110,444
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________________________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________________________________
`
`INTEL CORPORATION,
`Petitioner,
`v.
`PARKERVISION, INC.
`Patent Owner.
`_____________________________________
`
`Case No. IPR2020-01265
`Patent No. 7,110,444
`____________________________________________
`
`
`
`PETITIONER’S MOTION TO EXCLUDE EVIDENCE
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`
`
`
`
`
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`Case No. IPR2020-01265
`Patent No. 7,110,444
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`TABLE OF CONTENTS
`
`INTRODUCTION ........................................................................................... 1
`I.
`BACKGROUND ............................................................................................. 3
`II.
`III. EXHIBIT 2022 VIOLATES THE BOARD’S PROCEDURAL
`RULES AND SHOULD BE EXCLUDED ..................................................... 7
`IV. PATENT OWNER’S UNTIMELY EXHIBIT SHOULD BE
`EXCLUDED UNDER FRE 403.................................................................... 12
`CONCLUSION .............................................................................................. 15
`
`V.
`
`
`
`
`i
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`
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`Pursuant to 37 C.F.R. § 42.64(c), Petitioner moves to exclude Exhibit 2022
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`as (1) untimely and improper pursuant to 37 C.F.R. § 42.23(b) and the
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`Consolidated Trial Practice Guide (Nov. 2019) (“TPG”)1 and (2) as unfairly
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`prejudicial under Federal Rule of Evidence 403. See 37 C.F.R. § 42.62(a).
`
`Petitioner timely objected to Exhibit 2022 on September 17, 2021. (Paper 27.)
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`I.
`
`INTRODUCTION
`For the first time in its Sur-Reply, Patent Owner (“PO”) introduced a 25-
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`page exhibit (Ex. 2022) consisting of dozens of mathematically flawed calculations
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`prepared by its attorneys to support a late-breaking theory of patentability based on
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`the term “storage element” in Claim 3. The parties agree that patentability turns on
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`whether the Tayloe prior art reference discloses the required “storage element.”
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`The parties further agree that the “storage element” “stores non-negligible amounts
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`of energy from an input electromagnetic signal.” PO first proposed a construction
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`requiring the “stor[age] of non-negligible amounts of energy” in its POR
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`(Petitioner had not previously proposed construing this term). Despite proposing a
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`construction with this requirement, PO never argued in its POR that Tayloe lacks a
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`1 In its Order dated September 27, 2021, the Board authorized Petitioner to address
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`the untimeliness and impropriety of Patent Owner’s citation to Exhibit 2022 in its
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`Sur-Reply. (Paper 31, 2.)
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`1
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`
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`storage element that stores non-negligible amounts of energy. Instead, in its POR,
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`PO hinged its theory of patentability on another part of its proposed “storage
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`element” construction. For the first time in its Sur-Reply, however, PO argues that
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`Tayloe’s capacitors do not store “non-negligible” amounts of energy and that
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`Tayloe, therefore, does not disclose the required “storage element.” Specifically,
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`PO advances an entirely new theory of patentability in its Sur-Reply—that to
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`determine whether an element stores a non-negligible amount of energy requires
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`calculating what percentage of the total available energy in an input signal is stored
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`in the element. PO submitted Exhibit 2022—25 pages of attorney-prepared
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`mathematical equations—to purportedly show that Tayloe does not meet this new
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`test. Exhibit 2022 should be excluded for two reasons.
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`First, it is untimely and thus procedurally improper. PO first introduced
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`Exhibit 2022 with its Sur-Reply (Paper 26) on September 14, 2021, in violation of
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`37 C.F.R. § 42.23(b) and the Board’s rules. See 37 C.F.R. § 42.23(b) (“A sur-reply
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`… may not be accompanied by new evidence other than deposition transcripts of
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`the cross-examination of any reply witness.”); TPG at 73 (same). And PO’s tardy
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`disclosure has resulted in significant prejudice to Petitioner. See FRE 403. PO
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`raises the complicated calculations in Exhibit 2022 at a point when Petitioner
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`cannot fully respond—after the time when Petitioner could respond with expert
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`testimony or a written response. Forcing Petitioner to address these calculations
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`2
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`during an oral hearing without the benefit of briefing or expert testimony will
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`significantly prejudice Petitioner.
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`Second, Exhibit 2022 should be excluded under FRE 403. Exhibit 2022 is
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`an attorney-prepared document that, as Petitioner’s expert made clear at his
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`deposition, is riddled with unsupported assumptions and calculation errors.
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`Exhibit 2022 is thus not supported by any expert testimony and lacks the necessary
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`factual foundation to make it relevant evidence. And any purported relevance of
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`this unreliable document is substantially outweighed by the unfair prejudice and
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`confusion that it creates, particularly given that Petitioner will not have an
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`adequate opportunity to respond fully due to PO’s delinquent submission. See
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`FRE 403. Accordingly, the Board should exclude Exhibit 2022.
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`II. BACKGROUND
`The ’444 patent relates to a receiver for frequency down-converting a wireless
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`input signal. Claim 3 requires two “frequency down-conversion modules” for down-
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`converting the input signal, and each module comprises “a storage element.”
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`Petitioner did not propose construing “storage element” in its Petition, but PO
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`did so in its POR, proposing to construe the term as “an element of an energy transfer
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`system that stores nonnegligible amounts of energy from an input electromagnetic
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`signal.” (POR, 4.) Despite its proposed construction, PO made no argument that the
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`Tayloe reference fails to disclose “an element … that stores nonnegligible amounts
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`3
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`of energy from an input electromagnetic signal.” Instead, PO argued—based on the
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`“of an energy transfer system” language in its “storage element” construction—that
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`an “energy transfer system” required a low impedance load. (POR, 49 (“[S]torage
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`element is synonymous with a low impedance load.”).) PO then argued at length
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`that Tayloe does not disclose a low impedance load. (POR, 54-70, 72-75.)
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`In its Reply, Petitioner refuted PO’s unduly narrow construction of “storage
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`element” as requiring a “low impedance load.” Petitioner explained: (a) nothing in
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`the intrinsic evidence supports such a limitation of the term “storage element,”
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`(b) PO’s proposed “low impedance load” requirement is decisively contradicted by
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`claim 68 of the incorporated ’551 patent, which discloses that an energy transfer
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`embodiment can drive both low and high impedance loads, and (c) in any event,
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`Tayloe discloses a “low impedance load.” (Reply, 23-27.) Moreover, because PO
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`presented its “storage element” construction in its POR—and despite the fact that
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`PO had not disputed Tayloe’s storage of “non-negligible amounts of energy” in its
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`briefing—Petitioner responded to the POR by showing that Tayloe’s capacitors do,
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`in fact, store non-negligible amounts of energy. (Reply, 19-20.)
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`In the face of Petitioner’s evidence refuting PO’s “low impedance load”
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`argument, PO changed tack in its Sur-Reply. PO argues for the first time that
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`Tayloe’s capacitors do not store “non-negligible amounts of energy.” PO presents
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`a new argument—that to determine whether the storage element stores “non-
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`4
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`negligible amounts of energy,” one must calculate the amount of energy stored in
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`the element as a percentage of the total energy available in an input signal. (Sur-
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`Reply, 16.) According to PO, if the percentage is below a certain threshold—
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`which PO does not identify—the energy stored in the capacitors is “negligible” and
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`does not meet the patent’s “non-negligible” storage requirement. (See id.)
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`Exhibit 2022, cited in PO’s Sur-Reply, purports to perform these
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`calculations for Tayloe and the ’551 patent by using a “three-step” method for
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`determining whether an element stores non-negligible energy:
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`• (Step 1) “calculate the amount of energy that was available from the
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`input EM signal during a sampling aperture”;
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`• (Step 2) “compare it to the amount of energy transferred to the
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`element during that sampling aperture”; and
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`• (Step 3) “determine whether an element stores ‘non-negligible
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`amounts of energy.’”
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`(Sur-Reply, 17-18, n.14 (citing Ex. 2022).)
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`Exhibit 2022’s equations and calculations are presented with virtually no
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`context or attribution and without making any connection to Tayloe’s disclosure.
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`Nevertheless, for step 1, PO purports to calculate the amount of energy that is
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`available from the input EM signal by (a) setting the load resistance equal to the
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`source resistance (RL=RS) according to the “maximum power transfer theorem”
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`5
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`(Ex. 2022, 9; see also Sur-Reply, 19-20), (b) calculating the maximum power
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`delivered to the matched load as PMAX = 0.5 (VPEAK)2 / (RL), where VPEAK = ½
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`EPEAK (Ex. 2022, 10; see also Sur-Reply, 20), and (c) calculating the product of the
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`power delivered to the matched load and the time duration that the switch is on as
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`U = PL * TON (Ex. 2022, 11; see also Sur-Reply, 21.)
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`For step 2, PO purports to calculate the amount of energy transferred to the
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`element by (a) calculating the average voltage across the capacitor EAVG (Sur-
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`Reply, 21-22; see also Ex. 2022, 16), (b) determining the voltage of the capacitor
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`as VCAP = EAVG (1-e-TON/τ), where τ = RC (Ex. 2022, 14-17; see also Sur-Reply,
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`21-22), and (c) calculating the energy held by the capacitor as ECf = ½ C*(VCAP)2
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`(Ex. 2022, 7-8, 20; see also Sur-Reply, 22.)
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`Finally, for step 3, PO purports to determine whether the element stores non-
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`negligible amounts of energy by dividing the results of step 2 by the results of step
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`1. (Ex. 2022, 21; see also Sur-Reply, 22-23.)
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`Based on these calculations, PO argues that Tayloe’s capacitors store
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`0.193% of the total energy available in the input signal. PO concludes, without
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`support, that 0.193% indicates a negligible—not the required non-negligible—
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`amount of energy stored. (Sur-Reply, 22.)
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`Before submitting Exhibit 2022 in its Sur-Reply, PO used the exhibit during
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`the deposition of Petitioner’s expert, Dr. Subramanian. Even without any prior
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`6
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`opportunity to review this 25-page exhibit of complex mathematical calculations
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`and principles of physics, Dr. Subramanian noted numerous mathematical and
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`factual errors, and identified many assumptions embedded in PO’s calculations—
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`assumptions that PO has never shown, either during the deposition or in its Sur-
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`Reply, apply to the Tayloe reference. (E.g., Ex. 2028, 40:5-24, 50:3-51:9, 68:15-
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`70:3 (Subramanian identifying errors and inconsistencies in Ex. 2022), 26:2-79:22
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`(Subramanian and PO’s attorney making over 100 references to “assumptions”
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`underlying the calculations when discussing Ex. 2022).) Whereas PO’s attorney
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`asked Dr. Subramanian during the deposition to assume these assumptions were
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`correct (E.g., id. 30:6 (“Assume that that’s correct”), 46:19-20 (“assuming that the
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`assumptions that you mentioned earlier are also made”), 73:9 (“Yes, you can
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`assume that”)), PO does not address or explain them in the Sur-Reply and instead
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`misleadingly suggests that Dr. Subramanian agreed with Exhibit 2022 as written
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`(E.g., Sur-reply, 18 ((“Dr. Subramanian agreed”) 19 (“Intel’s expert agrees”)).
`
`III. EXHIBIT 2022 VIOLATES THE BOARD’S PROCEDURAL RULES
`AND SHOULD BE EXCLUDED
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`According to the Board’s procedural rules, PO must disclose all evidence of
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`patentability in its POR. See TPG, 74; 37 C.F.R. § 42.23(b). The PTAB forbids
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`introducing new patentability evidence in a Sur-Reply other than deposition
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`transcripts of the cross-examination of any reply witness. See § 42.23(b) (“A sur-
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`7
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`reply … may not be accompanied by new evidence other than deposition
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`transcripts of the cross-examination of any reply witness.”).
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`PO violated these clear procedures. In its Sur-Reply, PO alleges, for the first
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`time, that a three-step calculation is “necessary” to determine if an element “stores
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`a non-negligible amount of energy” as Claim 3 requires. (Sur-Reply, 16.) But PO
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`did not raise this alleged prima facie argument of patentability in its POR when it
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`first proposed the “non-negligible” energy requirement. TPG, 74 (“Examples of
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`indications that a new issue has been raised in a reply include new evidence
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`necessary to make out a prima facie case for the patentability” of a claim). Indeed,
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`the POR never made any attempt to argue that Tayloe’s capacitors do not store
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`non-negligible amounts of energy, much less propose the three-step calculation in
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`Exhibit 2022 that PO now alleges is “necessary” for an invalidity analysis.
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`PO’s expert, Dr. Steer, also failed to raise this issue, either in his declaration
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`or at his deposition. Indeed, at his deposition, Dr. Steer argued only that the
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`capacitors do not store non-negligible energy for driving a low-impedance load—
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`based on his argument that the claims require a low-impedance load and that
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`Tayloe uses a high-impedance load. (Ex. 1029-Steer Dep., 119:9-19 (“Q. Do the
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`capacitors 72, 74, 76, and 78, disclosed in Tayloe, store non-negligible amounts of
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`8
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`energy? … A. Well, the non-negligible energy that they store2 must drive a low
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`impedance load. So in that sense, the capacitors in Tayloe … do not store the non-
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`negligible energy that is described in the patent because that non-negligible energy
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`must be able to describe—must be able to drive a low impedance load.”).) Dr.
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`Steer never suggested anything like the three-step calculation that PO now
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`proposes.
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`Because Exhibit 2022—a 25-page document of mathematical calculations
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`and statements of physical principles prepared by counsel—constitutes “new
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`evidence” that is not a deposition transcript and would take the trial “in a new
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`direction with a new approach,” it is not compliant with § 42.23(b) or the TPG and
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`should be excluded. See TPG 74 (a PO’s ability to “‘[r]espond,’ [to Petitioner’s
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`Reply] in the context of 37 C.F.R. § 42.23(b), does not mean proceed in a new
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`direction with a new approach as compared to the positions taken in a prior
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`filing.”); Netflix, Inc. v. DivX, LLC, No. IPR2020-00511, 2021 WL 3599429, at
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`*23 (P.T.A.B. Aug. 13, 2021) (granting Petitioner’s Motion to Exclude exhibits
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`filed with Sur-Reply pursuant to 37 C.F.R. § 42.23(b), and not considering portions
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`of Sur-Reply relying on exhibits; “[W]e do not find it in the interests of justice to
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`maintain these exhibits in the case file.”). The PTAB has admonished patent
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`2 All emphasis is added unless otherwise noted.
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`9
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`owners for similar desperate attempts to rescue a patentability position. See 3M
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`Patent No. 7,110,444
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`Co. v. Westech Aerosol Corp., No. IPR2018-00576, 2019 WL 1878045, at *2
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`(P.T.A.B. Apr. 26, 2019) (granting Petitioner’s Motion to Strike) (“Only in its
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`Surreply and MTA Reply does PO raise its ‘solvent impurities theory’ for the first
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`time…. Thus, this ‘solvent impurities theory’ is not, as PO suggests, limited to
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`responding to arguments raised by Petitioner, but rather is an independent
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`argument that could have been (and should have been) raised in the POR, to
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`respond to Petitioner’s original priority and written description arguments.”)
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`(emphasis in original).
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`Moreover, because PO chose to present the exhibit and its complicated (and
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`flawed) calculations at a point in the trial when Petitioner cannot meaningfully
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`respond, Petitioner is deprived of the opportunity to (a) rebut the exhibit’s
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`calculations in a written response, (b) question PO’s expert on the assumptions and
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`bases for these calculations, and (c) present rebuttal expert testimony on the
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`subject. Further, Petitioner is faced with the difficult task of addressing Exhibit
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`2022’s complex equations—which are inaccurate and unsupported—orally during
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`10
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`the hearing without the benefit of expert testimony.3
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`The Board’s procedures are structured to prevent this type of prejudice.
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`Both the Board’s rules and its TPG require PO to present its patentability
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`arguments and evidence in the POR, precisely to allow Petitioner to fairly test
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`them. See 3M Co., 2019 WL 1878045 at *3 (P.T.A.B. Apr. 26, 2019) (“The reason
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`for limiting the scope of a reply (and surreply) is to promote procedural fairness….
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`Parties are charged with bringing their best arguments forward in a manner that
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`provides the opposing party an opportunity to fairly test those arguments.
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`Belatedly raising arguments for the first time in the final brief … does not permit
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`occasion to challenge those arguments in the absence of an endless parade of
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`additional briefing.”); Unified Patents, LLC v. American Patents, LLC, No.
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`IPR2019-00482, 2020 WL 1656238 at *3 (P.T.A.B. Apr. 3, 2020) (“[I]t would be
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`procedurally unfair to allow PO to argue diligence for the first time in its Sur-
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`Reply. At this point in the trial, Petitioner cannot meaningfully respond PO’s
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`belatedly introduced arguments, and PO provides no justification for its late
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`3 PO’s conclusion that Tayloe’s capacitors do not store non-negligible energy is
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`incorrect, and Petitioner will address the baselessness of PO’s argument if PO is
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`permitted to maintain its new theory of patentability based on the calculations in
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`Exhibit 2022.
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`11
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`introduction of these arguments.”).
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`In fact, the Board’s Scheduling Order in this case warned PO that “any
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`arguments not raised in the [PO] response may be deemed waived.” (Paper 11, 8.)
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`PO’s failure to comply with the Board’s procedural rules has caused significant
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`prejudice to Petitioner, warranting exclusion. See Lenovo Holding Co., Inc. v.
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`Dodots Licensing Sols. LLC, No. IPR2019-00988, 2020 WL 3067544, at *2–3
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`(P.T.A.B. June 9, 2020) (granting motion to strike untimely Exhibit 2007, which
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`contained “twelve dictionary definitions and articles purporting to construe the
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`term ‘template’”; “We are … persuaded that Petitioner would be unduly prejudiced
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`by PO’s belated and untimely introduction of [expert] declarations (Exs. 2005,
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`2006) and … Exhibit 2007 because Petitioner is unable to depose the two
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`declarants, and present evidence and arguments to rebut their testimony and PO’s
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`new arguments…. We note that PO could have, but did not, request permission to
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`submit new evidence in order to respond to purportedly ‘newly-raised arguments
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`or evidence’ in Petitioner’s Reply. We expressly cautioned that arguments not
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`presented by PO in its POR would be deemed waived.” (citations omitted)).
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`IV. PATENT OWNER’S UNTIMELY EXHIBIT SHOULD BE
`EXCLUDED UNDER FRE 403.
`PO’s last-ditch effort to salvage patentability by submitting an untimely
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`exhibit should also be rejected under FRE 403. See FRE 403. As explained
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`12
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`below, Exhibit 2022 is rife with incorrect calculations and unsupported
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`assumptions. These flaws make the document unreliable and negate any purported
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`relevance. Moreover, any relevance is substantially outweighed by the confusion
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`and unfair prejudice it creates, providing an independent basis for its exclusion
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`under FRE 403.
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`As noted above, even during the short period of time that Petitioner’s expert
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`could review the exhibit during his deposition, he identified multiple errors and
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`inconsistencies. (E.g., Ex. 2028, 40:5-24, 50:3-51:9, 68:15-70:3.) For example,
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`page 21 of Exhibit 2022 says, “[r]ecall that the energy transferred to a 1 µF
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`capacitor in 25 ns is UC = 0.5 pJ”—suggesting a reference to an earlier portion of
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`the document. But no other portion the exhibit discusses the amount of energy
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`transferred to a 1 µF capacitor in 25 ns. (Id., 68:15-70:3.) As another example,
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`page 13 incorrectly indicates that the sum of 0.02 and 0.0005 is 0.02005 instead of
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`0.0205. (Id., 50:3-51:9.) And page 8 has a series of mathematical errors based on
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`an incorrect voltage value (0.0001V rather than 0.001V). (Id., 40:5-24.)
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`Moreover, Petitioner’s expert identified numerous unsupported assumptions
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`underlying Exhibit 2022’s calculations. For example, the calculations assume that:
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`• the power P is held constant when calculating the energy delivered to a
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`resistor R. (Ex. 2028, 31:23-33:15 (assuming power “P” was a constant).)
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`• the voltage applied to the load resistor RL is a perfect sinusoid when
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`13
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`calculating available power that can be transferred to RL. (Id., 75:12-76:9
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`(“[T]hat’s true only for a perfect sinusoid.”), 45:24-46:23 (assuming voltage is
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`a pure sinusoid).)
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`• the time scale for TON encompasses a very large number of cycles of the
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`sinusoid when calculating the available energy during TON. (Id., 47:2-49:7.)
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`• the power source is a DC source when calculating the available energy during
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`a time TX. (Id., 66:1-8 (“Assuming the source is a DC source … then this
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`would be correct.”); id., 70:5-71:13 (“A: … Am I to assume that that’s a DC
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`power source so it’s not time varying, that is the power that’s available?
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`Q: Yes, DC power source.”).)
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`• the capacitor has no leakage/internal discharge path when calculating the
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`energy that has been transferred to the capacitor. (Id., 72:11-73:25.)
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`• the assumptions underlying the “maximum power transfer theorem” are met in
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`calculating the available power. (Id., 41:10-41:18 (“Q: Do you agree that the
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`information on this slide is correct? A: The information is correct under the
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`assumptions that are made for the maximum power transfer theorem. Q: And
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`what assumptions are being made on slide nine? A: So the assumptions that
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`are being made here are specifically that we are treating the source
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`specifically in this case as a source that can be modeled as a Thevenin
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`equivalent.”); 43:23-44:13 (“[A]ssuming we can model the source as an
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`14
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`equivalent of the form set forth herewith, in other words, a VS and RS … all
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`of those assumptions must be true for this math to be true”.).)
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`Neither the exhibit itself nor PO’s Sur-Reply provides any support for these
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`assumptions. Indeed, the exhibit’s contents are explained only by attorney
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`argument in PO’s Sur-Reply (Sur-Reply, 18-23), not by any expert testimony that
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`would link the calculations to Tayloe.
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`At bottom, Exhibit 2022 consists of 25 pages of complicated engineering
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`equations that lack any adequate foundation and are therefore not relevant to any
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`issue to be decided. Consideration of such incomplete, inaccurate, and
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`unsupported technical information—particularly where Petitioner has been
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`deprived of any adequate opportunity to respond because of the exhibit’s
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`untimeliness—would be both confusing and unfairly prejudicial to Petitioner.
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`Accordingly, Exhibit 2022 should be excluded under FRE 403.
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`V. CONCLUSION
`Petitioner respectfully requests that the Board exclude Exhibit 2022.
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`Date: October 7, 2021
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`Respectfully submitted,
`
`/Grant K. Rowan/
`Grant K. Rowan
`Registration No. 41,278
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`15
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`CERTIFICATE OF SERVICE
`I hereby certify that, on October 7, 2021, I caused a true and correct copy of
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`Case No. IPR2020-01265
`Patent No. 7,110,444
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`the foregoing materials:
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`• Motion to Exclude Evidence to be served via email, as consented to
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`by Patent Owner, to:
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`jcharkow@daignaultiyer.com
`cbiyer@daignaultiyer.com
`smandir@daignaultiyer.com
`
`
`
`/Grant K. Rowan/
`Grant K. Rowan
`Registration No. 41,278
`
`
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`16
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