UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________________
`
`QUALCOMM INCORPORATED and
`ZYXEL COMMUNICATIONS CORPORATION,
`
`Petitioner,
`
`v.
`
`UNM RAINFOREST INNOVATIONS,
`
`Patent Owner.
`_____________________
`
`Case IPR2021-00375
`
`Patent No. 8,265,096 B2
`_____________________
`
`PETITIONER’S SUR-REPLY IN OPPOSITION TO
`PATENT OWNER’S REVISED MOTION TO AMEND
`
`
`
`
`
`
`
`
`
`_____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________________
`
`QUALCOMM INCORPORATED and
`ZYXEL COMMUNICATIONS CORPORATION,
`
`Petitioner,
`
`v.
`
`UNM RAINFOREST INNOVATIONS,
`
`Patent Owner.
`_____________________
`
`Case IPR2021-00375
`
`Patent No. 8,265,096 B2
`_____________________
`
`PETITIONER’S SUR-REPLY IN OPPOSITION TO
`PATENT OWNER’S REVISED MOTION TO AMEND
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Table of Contents
`
`I.
`
`INTRODUCTION ............................................................................................... 1
`
`II. P.O.’S UNAUTHORIZED RMTA SHOULD BE EXPUNGED ....................... 1
`
`III. P.O. FAILED TO MEET ITS BURDEN TO SHOW WRITTEN
`DESCRIPTION SUPPORT ....................................................................................... 5
`
`A. P.O. Does Not Contest That Its Attempted Showing of Written
`Description on Reply Is Too Late .......................................................................... 5
`
`B. Even If Considered, the RMTA Does Not Satisfy P.O.’s Burden to
`Show Written Description .................................................................................... 10
`
`Patent Owner Admits that Even the RMTA Does Not Comply with
`1.
`37 C.F.R. § 42.121 ............................................................................................ 10
`
`Even If Considered, The String Citations in the RMTA Do Not
`2.
`Satisfy P.O.’s Burden to Show Written Description ......................................... 10
`
`IV. P.O.’S UNAUTHORIZED RMTA REPLY SHOULD BE EXPUNGED ....... 11
`
`V. P.O.’S PROPOSED SUBSTITUTE CLAIMS ARE UNPATENTABLE
`OVER THE PRIOR ART ........................................................................................ 12
`
`VI. CONCLUSION ................................................................................................. 12
`
`
`
`
`
`
`
`-i-
`
`
`
`
`
`I.
`
`INTRODUCTION
`
`P.O.’s Reply in support of its Revised Motion to Amend (Paper 54, “RMTA
`
`Reply”)1 confirms that, regardless of whether the Board considers P.O.’s Original
`
`Motion to Amend (Paper 37, “OMTA”) or Revised Motion to Amend (Paper 44,
`
`“RMTA”), both should be denied.
`
`II.
`
`P.O.’S UNAUTHORIZED RMTA SHOULD BE EXPUNGED
`
`P.O. does not dispute that its RMTA does not comply with requirement in the
`
`Pilot Program Notice to “include[] one or more new proposed substitute claims in
`
`place of previously presented substitute claims.” RMTA Reply at 3-4; 84 Fed. Reg.
`
`9497, 9498–99, 9501. Although P.O. cites a portion of the Notice indicating that a
`
`revised MTA may also include previously presented claims (RMTA Reply at 4), the
`
`Notice makes clear that a revised MTA may only maintain “some proposed
`
`substitute claims from the original MTA,” which is consistent with the requirement
`
`to “include[] one or more new proposed substitute claims.” 84 Fed. Reg. at 9501
`
`(emphasis added). P.O. attempts to circumvent the new-claim rule in the Pilot
`
`Program Notice by arguing it “serv[es] no meaningful purpose.” RMTA Reply at 4.
`
`In particular, P.O. hypothesizes that it could have complied with the new-claim rule
`
`“by simply adding a superficial and inconsequential amendment to create the illusion
`
`
`1 The RMTA Reply, Paper 54, is incorrectly labeled as Paper 52 on its first page.
`
`
`
`-1-
`
`
`
`
`
`of proper form.” Id. P.O. is wrong, as the Notice prohibits amendments unrelated to
`
`the preliminary guidance or the opposition to the MTA. See 84 Fed. Reg. 9497, 9498
`
`(“A revised MTA may not include amendments … that are unrelated to issues raised
`
`in the preliminary guidance and/or petitioner’s opposition to the MTA.”) (emphasis
`
`added). An “inconsequential amendment” as contemplated by P.O. would have
`
`failed this requirement. Thus, the failure to include new claims is fatal to P.O.’s
`
`RMTA.
`
`Moreover, P.O. does not dispute that its RMTA was unauthorized. RMTA
`
`Reply at 3-4; Orthofix Medical Inc. v. Spine Holdings, LLC, IPR2020-01411, Paper
`
`33 at 3 (PTAB Oct. 27, 2021) (“We … did not authorize Patent Owner to file [a
`
`revised MTA] without new proposed substitute claims.”). Nor does P.O. dispute that
`
`the Board may expunge its unauthorized paper. RMTA Reply at 3-4. Because P.O.’s
`
`RMTA failed to comply with the Pilot Program Notice instructions to which the
`
`Board had directed the parties (Paper 23 at 2), and P.O. failed to obtain permission
`
`to deviate from those instructions, the RMTA should be expunged. 37 C.F.R.
`
`§ 42.20(b); 37 C.F.R. § 42.7(a); Valeo, North America, Inc. v. Magna Elecs., Inc.,
`
`IPR2014-00227, Paper 44 at 2 (PTAB Jan. 14, 2015) (expunging unauthorized
`
`motion for “fail[ure] to comply with … instruction[s]” in a prior order, given that
`
`“Patent Owner did not initiate a conference call” to obtain authorization to deviate
`
`from those prior instructions).
`
`-2-
`
`
`
`
`
`Indeed, expungement is particularly warranted here because of the prejudice
`
`to Petitioner as a result of not knowing whether P.O.’s RMTA would be treated as a
`
`motion or a reply. In its RMTA Reply, P.O. now proclaims that—despite how it
`
`titled and styled the RMTA, despite giving itself 25 pages without seeking prior
`
`authorization to exceed the 12-page limit for a reply,2 and despite otherwise giving
`
`no indication to Petitioner (or the Board) it intended to proceed in reply-fashion—
`
`its RMTA was actually a reply all along, and P.O. had only styled it as an RMTA
`
`“out of an abundance of caution.” RMTA Reply at 3. Based on this retroactive
`
`proclamation, P.O. contends that Petitioner has “already taken advantage” of the
`
`same remedies provided in Orthofix Medical, IPR2020-01411, Paper 33—i.e.,
`
`clarity that a revised MTA was actually a reply, with an enlarged 25 pages to
`
`respond. RMTA Reply at 3.
`
`Even accepting arguendo P.O.’s attempt at revisionist history, Petitioner here
`
`received neither of the remedies that the Board applied in Orthofix Medical. First,
`
`due to the compressed schedule, Petitioner was unable to receive advance clarity that
`
`P.O.’s RMTA was actually a reply—a point P.O. does not dispute. Opp’n at 3-4
`
`(explaining that the schedule in this proceeding, which was three-times more
`
`compressed than the schedule in Orthofix Medical, prevented Petitioner from
`
`obtaining guidance from the Board in time to adjust its responsive paper); RMTA
`
`
`2 If deemed a reply, the Board should strike at least the unauthorized excess pages.
`
`-3-
`
`
`
`
`
`Reply at 3-4 (not disputing). This point is critical—because Petitioner did not know
`
`whether P.O.’s paper was a motion (as it purported to be) or a reply, in order to
`
`protect its interests, Petitioner was forced to respond as if it was both, including
`
`submitting new evidence in the event it was deemed a motion. 84 Fed. Reg. at 9501
`
`(new evidence permissible in opposition, but not on sur-reply). Second, Petitioner
`
`did not receive an enlarged 25-page limit for a sur-reply; instead, Petitioner only
`
`received 25 pages for a combined opposition and sur-reply. Again, because P.O.
`
`styled its paper as a revised motion, Petitioner had no choice but to raise its
`
`opposition arguments in full or risk waiver. 37 C.F.R. § 42.6(a)(3) (“Arguments
`
`must not be incorporated by reference from one document into another document.”);
`
`Alaska Fuel Distributors Inc. v. Frac Shack Inc., IPR2019-00995, Paper 32 at 18
`
`(PTAB Oct. 15, 2020) (“In its Opposition to the Revised Motion to Amend,
`
`Petitioner refers back to its Opposition to the original Motion to Amend…. We are
`
`doubtful that this manner of merely referring to arguments presented in an earlier
`
`brief, which opposed an earlier and different version of the motion to amend, is
`
`sufficient for Petitioner to preserve any new matter argument with respect to the
`
`Revised Motion to Amend.”). Accordingly, Petitioner received neither of the
`
`remedies available to the petitioner in Orthofix Medical, and fairness warrants a
`
`different result—expungement of P.O.’s RMTA.
`
`-4-
`
`
`
`
`
`Lastly, although P.O. attempts to claim it was prejudiced by only having one
`
`week to file its RMTA Reply following Petitioner’s Opposition (RMTA Reply at 4),
`
`the compressed schedule has been entirely of P.O.’s own making. First, P.O. delayed
`
`this proceeding by calling into question whether it had standing to participate (Paper
`
`18 at 2), but later dropped that position. Paper 21 (showing that P.O. has standing);
`
`Paper 22 (not disputing standing). Second, P.O. opted to pursue a motion to amend
`
`under the Pilot Program, aware of the attendant effects under an already compressed
`
`schedule. Papers 23, 26. And third, after filing a deficient MTA, P.O. chose to file a
`
`revised MTA, again cognizant of the attendant effects of the schedule. Paper 42. By
`
`rule, Petitioner was entitled to submit evidence with its opposition (84 Fed. Reg. at
`
`9501), and the compressed schedule provided P.O. one week to reply. P.O.’s cries
`
`of prejudice by having to comply with the schedule that it chose rings hollow.
`
`III. P.O. FAILED TO MEET ITS BURDEN TO SHOW WRITTEN
`DESCRIPTION SUPPORT
`A.
`
`P.O. Does Not Contest That Its Attempted Showing of Written
`Description on Reply Is Too Late
`
`P.O. attempts to save its unauthorized RMTA by welcoming reclassification
`
`as a reply, but if considered to be a reply, P.O. does not meaningfully dispute that its
`
`attempt to rectify the written description deficiency in its OMTA in a reply paper
`
`came too late. RMTA Reply at 5-6.
`
`-5-
`
`
`
`
`
`In both the RMTA and the RMTA Reply, P.O. did not dispute that it bears the
`
`burden of production to show written description support. RMTA at 5-13; RMTA
`
`Reply at 5-6; see Lectrosonics, Inc. v. Zaxcom, Inc., IPR2018-01129, Paper 15 at 8
`
`(P.T.A.B. Feb. 25, 2019) (precedential). Nor has P.O. ever disputed that the OMTA
`
`failed to address, in any fashion, the original claim limitations of the proposed
`
`substitute claims. OMTA at 4-6. Moreover, P.O. does not dispute that under Lippert
`
`Components, Inc. v. Days Corp., IPR2018-00777, Paper 28 at 51 (PTAB Sept. 24,
`
`2019), P.O.’s initial attempt to show written description support on reply came “too
`
`late.” RMTA Reply at 5-6. P.O. cites no contrary authority. Instead, P.O. seems to
`
`try and distinguish Lippert Components by arguing that the Preliminary Guidance
`
`either excused P.O. from meeting its burden or authorized a late showing of written
`
`description support on reply. Id.
`
`The Preliminary Guidance did neither. To the contrary, the Preliminary
`
`Guidance found that P.O.’s OMTA had not met its burden to show written
`
`description support. Paper 42 at 6. And the Preliminary Guidance did not give any
`
`authorization for a late showing of written description support on reply. Id. P.O. cites
`
`no authority for the extraordinary proposition that the Board’s Preliminary Guidance
`
`shifted a burden that P.O. had not met to Petitioner. Nor has P.O. cited any authority
`
`for the extraordinary proposition that the Board’s Preliminary Guidance waived the
`
`requirements of 37 C.F.R. §§ 42.121(b) and 42.23(b) that P.O.’s motion to amend
`
`-6-
`
`
`
`
`
`(rather than a reply) include P.O.’s arguments necessary to set forth a prima facie
`
`showing of written description support.
`
`Accordingly, P.O.’s new written description arguments on reply came too
`
`late. Lippert Components, IPR2018-00777, Paper 28 at 51 (“[T]he attempt” to make
`
`an initial showing of written description support on reply “came too late.”); Free
`
`Stream Media Corp. v. Gracenote, Inc., IPR2020-00219, Paper 36 at 32 (PTAB June
`
`15, 2021) (denying motion to amend, “find[ing] that Patent Owner did not identify
`
`in the RMTA the material at column 8 of the ’030 patent and in the Background
`
`section, as our rules require, and that the RMTA Reply is too late to raise new
`
`evidence.”); Respironics, Inc. v. Zoll Med. Corp., No. IPR2013-00322, Paper 46 at
`
`25 (PTAB Sept. 17, 2014) (“Zoll’s Reply in support of its Motion to Amend seeks
`
`to remedy the [written description] problem, but it is too little, too late”). In
`
`particular, Respironics explained that “[a] Reply affords the moving party an
`
`opportunity to refute arguments and evidence advanced by the opposing party, not
`
`an opportunity to improve its position.” Id. Like the patent owner in Respironics,
`
`P.O.’s “new [reply] evidence” was “offered to bolster [P.O.’s] motion, not to refute
`
`argument or evidence by [Petitioner] that the claim lacks adequate written
`
`description support,” and P.O. has “not explain[ed] why it could not have presented
`
`[the] Reply [written description] evidence with its motion.” Id. Accordingly, P.O.
`
`“has not shown why this late evidence should be considered.” Id.
`
`-7-
`
`
`
`
`
`To be clear, P.O.’s motion to amend should be denied because P.O. has failed
`
`to satisfy its burden under 35 U.S.C. § 316(d) and 37 C.F.R. § 42.121 to show written
`
`description support for the proposed substitute claims. In that regard, it is also worth
`
`noting that no finding of inadequate written description is necessary, as requiring
`
`such would impermissibly shift the burden to Petitioner. Respironics, IPR2013-
`
`00322, Paper 46 at 26 (“We do not conclude that Zoll’s proposed claim 36 lacks the
`
`support of adequate written description. Instead, we conclude that Zoll has not come
`
`forward with sufficient evidence to demonstrate that claim 36 has the required
`
`support.”); Lippert Components, IPR2018-00777, Paper 28 at 52-56 (denying MTA
`
`on the basis that P.O. had not met its burden of production to show written
`
`description support despite finding adequate written description support for the only
`
`claim limitation contested by Petitioner).
`
`Lastly, P.O. attempts to excuse its mistake by arguing that Petitioner has had
`
`a full opportunity to address the RMTA’s new written description arguments. RMTA
`
`Reply at 6. P.O. is incorrect. First, this argument ignores that P.O. was obligated to
`
`include its written description support in its OMTA to give Petitioner a fair
`
`opportunity to respond. See Lippert Components, IPR2018-00777, Paper 28 at 51
`
`(finding that MTA that did “not address, in any fashion, the limitations of the
`
`existing claims that are carried forward in the proposed claims” did not “accord[]”
`
`Petitioner “a fair opportunity to address [the] issue,” as “there was nothing for
`
`-8-
`
`
`
`
`
`Petitioner to oppose … when filing the initial opposition.”); Unified Patents Inc. v.
`
`Velos Media LLC, IPR2019-00707, Paper 55 at 30 (PTAB Sept. 3, 2020) (In
`
`assessing written description support in a motion to amend, the Board “consider[s]
`
`whether Patent Owner reasonably asserted support such that Petitioner could
`
`respond.”). Second, if the RMTA is considered to be a reply, then Petitioner’s
`
`responsive paper would be a sur-reply, and Petitioner no longer had the opportunity
`
`to submit responsive evidence. 84 Fed. Reg. at 9500 (“[N]ew evidence (including
`
`declarations) may be submitted with every paper in the MTA process, except a sur-
`
`reply. A sur-reply may only include cross-examination deposition transcripts.”). As
`
`such, Petitioner would have been unable to submit a declaration from its expert that
`
`responded to P.O.’s new written description theories. Moreover, P.O. did not support
`
`its new RMTA written description arguments with a declaration from its expert, so
`
`Petitioner did not even have the opportunity to submit rebuttal evidence in the form
`
`of a cross examination deposition transcript.
`
`And P.O.’s argument that Petitioner “did in fact address the written
`
`description support proffered by Patent Owner” is wrong. RMTA Reply at 6 (citing
`
`Petitioner’s RMTA Opp’n at 7-10). There, Petitioner’s RMTA Opp’n explained that
`
`P.O.’s string citations lacked the explanation necessary to show written description
`
`support. But that argument, which did not require support from an expert declaration,
`
`-9-
`
`
`
`
`
`does not negate that P.O.’s error has deprived Petitioner from being able to fully
`
`respond to the RMTA’s new written description arguments with expert evidence.
`
`B.
`
`Even If Considered, the RMTA Does Not Satisfy P.O.’s Burden to
`Show Written Description
`1.
`
`Patent Owner Admits that Even the RMTA Does Not
`Comply with 37 C.F.R. § 42.121
`
`37 C.F.R. § 42.121 requires that “a motion to amend claims must … set forth
`
`… the support in an earlier filed disclosure for each claim for which benefit of the
`
`filing date of the earlier filed disclosure is sought.” 37 C.F.R. § 42.121(b)(2). P.O.
`
`does not even attempt to argue that its RMTA complied with this requirement –
`
`instead P.O. takes the position that this requirement “is irrelevant.” RMTA Reply
`
`at 8. P.O. argues that because the RMTA motion is contingent on a finding that
`
`claim 1 of the ’096 has been shown to be unpatentable, P.O. need not comply with
`
`the regulations. Id. at 8–9. The requirements of 37 C.F.R. § 42.121 expressly apply
`
`to all motions to amend, and P.O. cites to no contrary authority. Because P.O. does
`
`not dispute that even its RMTA does not meet its burden to produce written
`
`description support, the motion must be denied for this reason alone.
`
`2.
`
`Even If Considered, The String Citations in the RMTA Do
`Not Satisfy P.O.’s Burden to Show Written Description
`
`In its opposition to P.O.’s RMTA, Petitioner cited numerous decisions in
`
`which the Board has found string citations to be insufficient to satisfy a patent
`
`owner’s burden to show written description support. Paper 47 at 8-11. P.O. attempts
`
`-10-
`
`
`
`
`
`to distinguish just one of those decisions, Lippert Components, on the basis that
`
`there, the deficient string citations did not reproduce the quoted text, whereas P.O.’s
`
`string citations did reproduce the quoted text. RMTA Reply at 5-6.
`
`P.O.’s argument misses the point. Its bare string citations with only quoted
`
`text were “without explanation” and therefore “are insufficient to meet a patent
`
`owner’s burden of production.” Lippert Components, IPR2018-00777, Paper 28 at
`
`52; Investors Exchange LLC v. Nasdaq, Inc., CBM2018-00039, Paper 47 at 55
`
`(PTAB Feb. 25, 2020) (“Patent Owner’s string citations to various disclosures is
`
`insufficient to demonstrate written description support absent some additional
`
`explanation”) (emphasis added). Even extensive quotation of a disclosure fails to
`
`demonstrate written description without adequate explanation. Apple Inc. v.
`
`Personalized Media Comms, LLC, IPR2016-00755, Paper 42 at 72-73 (PTAB Sept.
`
`19, 2017), rev’d on other grounds, 952 F.3d 1336 (Fed. Cir. 2020) (finding that “[a]
`
`long citation” with extensive quotes from the disclosure “fails to present a coherent
`
`explanation of how the disclosure provides written description support”).
`
`IV. P.O.’S UNAUTHORIZED RMTA REPLY SHOULD BE EXPUNGED
`
`P.O.’s insistence that it intended its RMTA to be a reply (RMTA Reply at 3-
`
`4) is belied by P.O. filing its RMTA Reply. If P.O.’s RMTA is considered a reply,
`
`then Petitioner’s opposition would be considered a sur-reply, and the Pilot Program
`
`-11-
`
`
`
`
`
`Notice does not authorize further papers. 84 Fed. Reg. at 9500–01. Accordingly, the
`
`RMTA Reply should be expunged.
`
`V.
`
`P.O.’S PROPOSED SUBSTITUTE CLAIMS ARE UNPATENTABLE
`OVER THE PRIOR ART
`
`Assuming, arguendo, that P.O.’s OMTA and/or RMTA complied with the
`
`statutory and regulatory requirements to meet their burden of production, the
`
`proposed substitute claims would still not overcome the prior art challenges.
`
`As described in detail in Petitioner’s Opposition, the combination of Talukdar
`
`and Li disclose all elements of claim 1 of the ’096 Patent, including the limitation
`
`“wherein each symbol in the second communication system has a shorter symbol
`
`period than that in the first communication system.” Patent Owner has argued from
`
`its first substantive paper that the limitation “wherein the second communication
`
`system has pilot symbols that are denser than those in the first communication
`
`system” is “a natural result” of shorter symbol period, because of the claim
`
`construction. See Prelim. Resp. at 36. Because that limitation is the only limitation
`
`added to the Proposed Amended Claims, they are invalid over the combination of
`
`Talukdar and Li for the reasons presented in the Petition and the Opposition.
`
`VI. CONCLUSION
`
`For the above reasons, P.O.’s OMTA and/or RMTA should be denied.
`
`Dated: May 9, 2022
`
`Respectfully submitted,
`
`/s/ Jonathan I. Detrixhe
`
`-12-
`
`
`
`
`
`
`
`Lead Counsel
`Jonathan I. Detrixhe (Reg. No. 68,556)
`Reed Smith LLP
`101 Second Street
`Suite 1800
`San Francisco, CA 94105
`Tel: 415.543.8700
`Fax: 415.391.8269
`jdetrixhe@reedsmith.com
`
`Back-up Counsel
`Jonah D. Mitchell (admitted hac vice)
`Christine M. Morgan (admitted pro hac vice)
`Reed Smith LLP
`101 Second Street
`Suite 1800
`San Francisco, CA 94105
`Tel: 415.543.8700
`Fax: 415.391.8269
`jmitchell@reedsmith.com
`cmorgan@reedsmith.com
`
`Peter J. Chassman (Reg. No. 38,841)
`Michael J. Forbes (Reg. No. 73,898)
`Reed Smith LLP
`811 Main Street
`Suite 1700
`Houston, TX 77002
`Tel: 713.469.3800
`Fax: 713.469.3899
`pchassman@reedsmith.com
`mforbes@reedsmith.com
`
`Counsel for Petitioner
`
`-13-
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. §§ 42.6(e)(4) and 42.25(b), the undersigned certifies
`
`that on May 9, 2022, a complete copy of Petitioner’s Sur-Reply in Opposition to
`
`Patent Owner’s Revised Motion to Amend was filed electronically through the
`
`Patent Trial and Appeal Board’s PTABE2E System and provided, via electronic
`
`service, to the Patent Owner by serving the correspondence address of record.
`
`Dated: May 9, 2022
`
`Respectfully submitted,
`/ Jonathan I. Detrixhe /
`Jonathan I. Detrixhe (Reg. No. 68,556)
`Reed Smith LLP
`101 Second Street
`Suite 1800
`San Francisco, CA 94105
`Tel: 415.543.8700
`Fax: 415.391.8269
`jdetrixhe@reedsmith.com
`
`Counsel for Petitioner
`
`
`
`14
`
`
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