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`UNITED STATES PATENT AND TRADEMARK OFFICE
`___________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
`
`
`TCT MOBILE (US), INC.; TCT MOBILE (US) HOLDINGS, INC.;
`HUIZHOU TCL MOBILE COMMUNICATION CO. LTD.; AND
`TCL COMMUNICATION, INC.,
`Petitioner,
`
`v.
`
`FUNDAMENTAL INNOVATION SYSTEMS INTERNATIONAL LLC,
`Patent Owner.
`
`___________________
`
`Case IPR2021-00599
`Patent No. 7,834,586
`___________________
`
`
`PATENT OWNER’S OPPOSITION TO
`PETITIONERS’ MOTION TO EXCLUDE
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`
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`
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`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`11099356
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`Case IPR2021-00599
`Patent No. 7,834,586
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`
`TABLE OF CONTENTS
`
`Page
`Factual Background ...................................................................................... 1
`A.
`EX2030 was introduced to refresh Dr. Baker’s memory ................... 1
`B.
`Patent Owner cited EX2030 in only two instances ............................ 3
`C.
`Petitioners did not object to other non-transcript exhibits
`submitted with the sur-reply ............................................................... 5
`Argument ...................................................................................................... 5
`A.
`Petitioners’ motion to exclude is an unauthorized motion to
`strike in disguise ................................................................................. 5
`Petitioners have an obligation to inform the Board of their
`inconsistent positions ......................................................................... 6
`Petitioners suffer no prejudice because EX2030 was authored
`by Petitioners’ expert and the two citations do not exceed the
`scope of a sur-reply ............................................................................ 7
`
`B.
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`C.
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`- i -
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`I.
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`II.
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`TABLE OF AUTHORITIES
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`Case IPR2021-00599
`Patent No. 7,834,586
`
`
` Page(s)
`
`Cases
`Netflix, Inc. v. DivX, LLC,
`IPR2020-00511, Paper 34 (PTAB, Apr. 13, 2021) .......................................... 3, 6
`Netflix, Inc. v. DivX, LLC,
`IPR2020-00511, Paper 46 (PTAB, Aug. 13, 2021) .................................. 1, 3, 8, 9
`Regulations
`37 C.F.R. § 42.51(b)(1)(iii) .......................................................................... 4, 6, 7, 10
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`Case IPR2021-00599
`Patent No. 7,834,586
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`EXHIBIT LIST
`
`Telephonic Hearing Transcript dated March 25, 2021
`EX2001
`EX2002 U.S. Patent No. 7,360,004 (“Dougherty”)
`EX2003
`Jan Axelson, USB Complete (1999), excerpt
`EX2004 U.S. Patent No. 5,884,086 (“Amoni”)
`EX2005 U.S. Patent No. 6,904,488 (“Matusmoto”)
`EX2006
`Jan Axelson, USB Complete (2d ed. 2001), excerpt
`EX2007 U.S. Patent No. 5,859,522 (“Theobald”)
`EX2008 U.S. Patent No. 6,556,564 (“Rogers”)
`EX2009 Declaration of Kenneth Fernald, Ph.D. in Support of
`Fundamental Innovation Systems International LLC’s Patent
`Owner Preliminary Response
`Claim construction order in Fundamental Innovation Systems
`International LLC v. Samsung Electronics Co., Ltd., Case No.
`2:17-cv-145-JRG-RSP, Dkt. No. 140 (E.D. Tex. Jan. 31, 2018)
`Claim construction order in Fundamental Innovation Systems
`International LLC v. LG Electronics Inc., Case No. 2:16-cv-
`1425-JRG-RSP, Dkt. No. 146 (E.D. Tex. April 2, 2018)
`
`EX2010
`
`
`EX2011
`
`
`EX2012
`
`
`Claim construction order in Fundamental Innovation Systems
`International LLC v. ZTE Corp. et al., Case No. 3:17-cv-1827-
`N, Dkt. No. 135 (N.D. Tex. Dec. 21, 2018)
`EX2013 Claim construction order in Fundamental Innovation Systems
`International LLC v. TCT Mobile (US), Inc., Case No. 20-cv-
`552-CFC-CJB, Dkt. No. 41 (D. Del. Feb. 12, 2021)
`EX2014 USB 2.0 Specification
`EX2015 USB 2.0 Specification Engineering Change Notice (ECN) #1:
`Mini-B connector dated Oct. 20, 2000
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`EX2017
`
`EX2018
`
`EX2022
`
`EX2016 History of Cell Phone Batteries and Advances in Technology,
`downloaded from https://medium.com/@diamondlitty62/history-
`of-cell-phone-batteries-and-advances-in-technology-
`9303f6cddd69 on December 13, 2021
`Battery University, “BU-107: Comparison Table of Secondary
`Batteries,” downloaded from
`https://batteryuniversity.com/article/bu-107-comparison-table-
`of-secondary-batteries, on December 13, 2021
`Battery Charging Specification v. 1.2 with errata, dated March
`15, 2012
`EX2019 Deposition transcript of Mr. John Garney in Fundamental
`Innovation Systems International LLC v. Samsung Electronics
`Co., Ltd., Case No. 2:17-cv-145-JRG-RSP, E.D. Tex., dated
`November 20, 2017
`Jan Axelson, USB Complete (2d ed. 2001), additional excerpt
`EX2020
`EX2021 Hyde, J., “USB Design by Example: A Practical Guide to
`Building I/O Devices,” Wiley Computer Publishing (1999)
`“Universal Serial Bus on-the-Go for Portable Device” dated Feb.
`29, 2000
`EX2023 Declaration of Kenneth Fernald, Ph.D. in Support of
`Fundamental Innovation Systems International LLC’s Patent
`Owner Response
`EX2024 Deposition transcript of Dr. R. Jacob Baker, dated November 23,
`2021
`EX2025 Deposition transcript of Dr. R. Jacob Baker, dated April 4, 2022
`EX2026
`Errata for Deposition transcript of Dr. Fernald dated February
`18, 2022 (EX1021)
`Reserved
`
`EX2027-
`EX2029
`EX2030 Dr. Baker’s expert report in the Fundamental Innovation
`Systems Int’l LLC v. TCT Mobile (US), Inc. et al., No. 1:20-cv-
`00552-CFC (D. Del.) dated March 15, 2022, used at Dr. Baker’s
`deposition on April 4, 2022
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`EX2031 Demonstrative created by Dr. Baker on April 4, 2022
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`Patent No. 7,834,586
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`Case IPR2021-00599
`Patent No. 7,834,586
`Petitioners have filed an unauthorized motion to strike disguised as a motion
`
`to exclude, seeking to strike Exhibit 2030 (“EX2030”), a report authored by
`
`Petitioners’ own expert, Dr. Baker, in the parallel district court case. See EX2030-
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`p. 1. This fact alone distinguishes it from Netflix, Inc. v. DivX, LLC, IPR2020-
`
`00511, Paper 46 at 55 (PTAB, Aug. 13, 2021) where the witness “repeatedly
`
`testified that he had not seen the exhibits” at issue. Moreover, Patent Owner only
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`introduced EX2030 because Dr. Baker was unable to recall what references he had
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`included in his district court report that he had signed less than three weeks before
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`the deposition. See EX2025 at 45:11-46:2. Notably, Petitioners do not claim
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`prejudice or contend that the two sentences in the sur-reply that cited EX2030
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`exceeded the allowed scope. Mtn. 1-2. Because EX2030 is an integral part of Dr.
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`Baker’s deposition transcript and does not prejudice Petitioners, the Board should
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`deny Petitioners’ unauthorized motion to strike in the interests of justice.
`
`I.
`
`Factual Background
`A. EX2030 was introduced to refresh Dr. Baker’s memory
`EX2030 is Dr. Baker’s district court report, originally due on March 8, 2022,
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`one day after the due date of the Reply in this proceeding. EX2025 at 45:1-6;
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`Paper 16 at 2. Petitioners accelerated the filing of the Reply to March 4, while
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`extending the district court report deadline by one week to March 15, 2022. See
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`Paper 19; EX2030-p. 1.
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`Patent No. 7,834,586
`EX2030 was introduced during Dr. Baker’s deposition on April 4, 2022,
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`when—less than three weeks after he submitted the validity report in the district
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`court case—Dr. Baker could not even recall whether he had asserted certain
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`references in the report:
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`Q: So the expert report in the District Court case, in that report, you did
`not asset the Morita reference; is that correct?
`
`A: I believe that's the case, but I'm -- I don't entirely remember, since it
`was a month ago.
`
`Q. Did you assert Casebolt and Cypress in that report?
`
`A: I don't remember.
`
`Q: Would it be helpful if I provide a copy of the report?
`
`A. Yes.
`
`Q. Okay. Hold [on] a minute. I'm trying to move the exhibit into the
`Marked Exhibits share folder. Give it a second. Okay. It should be
`there.
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`And I have labeled that particular exhibit as Exhibit 2030. 2030.
`
`Q. Do you see it, Dr. Baker?
`
`A: I have the report.
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`EX2025 at 45:11-46:15 (objections omitted). The exhibit was thus introduced to
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`refresh Dr. Baker’s memory with Dr. Baker’s consent.
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`B.
`Patent Owner cited EX2030 in only two instances
`The sur-reply cited EX2030 in two places: footnote 2 of page 1 and line 5 of
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`page 13 of the sur-reply. The reference to EX2030 on page 30 of Paper 24 was
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`part of the certificate of service indicating which documents and exhibits had been
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`served. Sur-reply at 30. Petitioners do not allege that any content in the sur-reply,
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`including the two sentences citing to EX2030, exceeded the permitted scope of a
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`sur-reply. Mtn. 1-2. This differs from Netflix, where such allegations were made.
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`Netflix, Inc. v. DivX, LLC, IPR2020-00511, Paper 34 at 1 (PTAB, Apr. 13, 2021).
`
`Citation on sur-reply 1, n2 Petitioners’ district court invalidity report did not
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`assert Morita and several references that Petitioners allege for the first time in the
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`Reply disclosed a “signal that identifies a power source type”; and Patent Owner
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`pointed out this fact in footnote 2 of the sur-reply. See sur-reply 1 n.2 (citing
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`EX2030-pp. 71-72 and the corresponding testimony EX2025 at 46:17-47:9).1
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`Although Patent Owner planned to elicit this fact without introducing the exhibit,
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`Dr. Baker’s inability to recall what references he relied on barely three weeks
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`before the deposition necessitated the use of EX2030 to refresh Dr. Baker’s
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`1 Petitioners incorrectly asserted that Patent Owner “d[id] not even cite
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`corresponding deposition testimony about Exhibit 2030.” Contra Mtn. 1.
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`memory. See EX2025 at 45:11-46:15 (quotation on page 2). Once introduced, the
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`exhibit became an integral part of the deposition and the transcript.
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`Citation on sur-reply 13 Petitioners and Dr. Baker’s stated claim
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`construction position on “identification signal” in the district court report is
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`inconsistent with the position they take—again for the first time in the Reply—in
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`this proceeding. See EX2030-p.231 n.3, EX1026, ¶ 32. Patent Owner’s counsel
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`was unaware of such inconsistency, or even that Dr. Baker had submitted a report
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`in the district court, when she communicated with Petitioners’ counsel on March
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`16, 2022.2 See EX1028. The sur-reply explained why Dr. Baker’s opinion in
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`footnote 3 on PDF page 231 of the district court report supports Patent Owner’s
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`claim interpretation, and undermines Petitioners’ new argument. See sur-reply at
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`12-13; see also EX2025, 204:5-208:25 (questions directed to the substance in
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`EX2030-p.231 n.3 and EX1026, ¶ 32). Under 37 C.F.R. § 42.51(b)(1)(iii),
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`Petitioners have an obligation to make the Board aware of evidence that is
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`inconsistent with the positions they have taken.
`
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`2 Unlike Patent Owner’s IPR counsel, Orrick represented Petitioners in both
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`the district court and this proceeding and should therefore have been aware of the
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`positions taken in the two fora.
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`C.
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`Case IPR2021-00599
`Patent No. 7,834,586
`Petitioners did not object to other non-transcript exhibits
`submitted with the sur-reply
`For completeness of record, Patent Owner also filed Exhibits 2026 and 2031
`
`
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`with its sur-reply. Exhibit 2026 (“EX2026”) is the errata to Exhibit 1021
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`(“EX1021”), Dr. Fernald’s deposition transcript filed with Petitioner’s Reply.
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`Exhibit 2031 (“EX2031”) is a drawing that Dr. Baker created during his
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`deposition, of his own volition. EX2025, 89:8-92:2. Petitioners do not object to
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`either exhibit even though both are filed as separate documents from the Baker
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`transcript, Exhibit 2025 (“EX2025”). This makes sense, because EX2026 is an
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`integral part of EX1021 and EX2031 is an integral part of EX2025. The same
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`applies to EX2030, which became an integral part of EX2025 when Patent Owner
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`was forced to introduce it to refresh Dr. Baker’s memory.
`
`II. Argument
`A.
`Petitioners’ motion to exclude is an unauthorized motion to strike
`in disguise
`Petitioners’ motion is a disguised motion to strike, as Petitioners’ objection
`
`lies in EX2030 being filed with the sur-reply instead of its admissibility under the
`
`Federal Rules of Evidence. Mtn. 1-2. The proper course should therefore have
`
`been a motion to strike, which requires prior authorization, instead of a pre-
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`authorized motion to exclude. See Trial Practice Guide (Nov. 2019) at 79 (“A
`
`motion to exclude must explain why the evidence is not admissible (e.g., relevance
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`Patent No. 7,834,586
`or hearsay) ….”); 80 (“If a party believes that a brief filed by the opposing party
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`raises new issues, is accompanied by belatedly presented evidence, or otherwise
`
`exceeds the proper scope of reply or sur-reply, it may request authorization to file
`
`a motion to strike.”). Petitioners have not sought or received authorization to file a
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`motion to strike, and its motion is therefore procedurally improper. See also id. at
`
`81 (“Generally, authorization to file a motion to strike should be requested within
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`one week of the allegedly improper submission. The Board will consider such
`
`requests on a case-by-case basis.”).
`
`This was the procedure that Netflix followed in IPR2020-00511, where
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`Netflix sought permission to file a motion to strike the exhibits at issue. IPR2020-
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`00511, Paper 34 at 1. In response, the Board authorized Netflix to lodge their
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`request in a motion to exclude. Id. at 2. No such authorization took place here and
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`Petitioners’ motion should therefore be denied on the procedural ground alone.
`
`B.
`
`Petitioners have an obligation to inform the Board of their
`inconsistent positions
`37 C.F.R. § 42.51(b)(1)(iii) provides:
`Unless previously served, a party must serve relevant information that
`is inconsistent with a position advanced by the party during the
`proceeding concurrent with the filing of the documents or things that
`contains the inconsistency.
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`Patent No. 7,834,586
`Petitioners may argue that because EX2030 was finalized after the March 4 Reply
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`filing, they were not subject to the above obligation. Taken to the extreme, such a
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`position would encourage gamesmanship by parties to time the submissions in
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`different fora to circumvent the disclosure requirement under § 42.51(b)(1)(iii). To
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`the extent that the opinion in the cited portion of EX2030-p.231 n.3 existed or was
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`reasonably expected to be included in the final draft, Petitioners’ counsel should
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`have disclosed the information under § 42.51(b)(1)(iii). Otherwise, parties would
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`have an incentive to keep material information from the Board. Patent Owner’s
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`submission therefore furthers the spirit of § 42.51(b)(1)(iii) and ensures that the
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`Board is kept abreast of the positions that Petitioners have taken elsewhere. Thus,
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`the inclusion of EX2030 is in the interests of justice, including in maintaining the
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`integrity of the PTAB proceedings.
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`C.
`
`Petitioners suffer no prejudice because EX2030 was authored by
`Petitioners’ expert and the two citations do not exceed the scope
`of a sur-reply
`Petitioners’ motion fails to mention that EX2030 is a district court expert
`
`report authored by the very same expert that they hired for this proceeding. The
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`motion also fails to inform the Board that the document was not served in the
`
`district court until March 15, rendering it impossible for Patent Owner to have
`
`submitted it with its POR. Moreover, given that Petitioners and Dr. Baker created
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`EX2030, they should be familiar with the content and the opinions contained
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`Patent No. 7,834,586
`therein. There is therefore no “sandbagging” by Patent Owner, as Petitioners
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`incorrectly allege. Contra Mtn. 2.3 Indeed, Petitioners alone controlled when
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`EX2030 was created relative to the deadlines of this trial and what was expressed
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`in the report.
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`The motion also fails to mention the circumstances under which the exhibit
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`was introduced, that is, to refresh Dr. Baker’s memory when Dr. Baker purported
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`not to recall what references he had used in the district court report that he had
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`signed less than three weeks before. See Section I.A. Before introducing EX2030,
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`Patent Owner’s IPR counsel specifically asked Dr. Baker whether it would have
`
`been helpful for him to see a copy of the report and he confirmed. EX2025, 45:25-
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`46:2. This exchange, as well as the exchange in 204:5-208:25, makes clear that
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`Patent Owner tried to elicit facts and opinions underlying EX2030, but Dr. Baker’s
`
`inability to recall basic facts made it necessary to introduce and cite to the exhibit.
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`The facts here differ materially from that of Netflix, the sole authority relied
`
`
`3 Any sandbagging that occurred in this proceeding came from Petitioners
`
`when it repeatedly raised new and incorrect arguments in the reply, knowing that
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`Patent Owner could not submit another declaration to rebut all the flawed and
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`inaccurate assertions in the reply and the supplemental declaration.
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`on by Petitioner. There, the deponent “repeatedly testified that he had not seen the
`
`[multiple] exhibits.” Netflix, Paper 46 at 55. Dr. Baker never asserted that the
`
`exhibit was new or unfamiliar to him; nor could he. EX2030’s cover page bears
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`his signature. EX2030-p.1. Unsurprisingly, because EX2030 is a document
`
`supposedly created by Dr. Baker and because Petitioners’ counsel had ample
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`opportunity to redirect Dr. Baker on the report,4 Petitioners do not allege any
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`prejudice caused by the sur-reply’s two citations to EX2030. Contra, Netflix,
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`Paper 46 at 53 (Netflix alleged prejudice by the new exhibits).
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`The facts here also differ because unlike Netflix, where the Patent Owner
`
`could have obtained similar information through cross-examination, (see Netflix,
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`Paper 46 at 55), the witness’s inability to recall the basic facts of his report made it
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`necessary for Patent Owner to introduce EX2030 to make it part of the deposition
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`and therefore properly part of the transcript. EX2025, 45:11-46:2, 204:5-208:25.
`
`Furthermore, unlike Netflix, where the new exhibits appeared to have been
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`relied on extensively (see Netflix, Paper 46 at 55-56), Patent Owner cited EX2030
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`sparingly:
`
`(1) to inform the Board that Dr. Baker had dropped Morita, Casebolt,
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`Cypress and Zyskowski against the ‘586 patent in the district court. Sur-reply at 1
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`4 See EX2025, 227:21-236:20 (redirect by Petitioners’ counsel).
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`n.2. That fact, coupled with Petitioners’ resort to whole new arguments and
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`effective abandonment of their original unpatentability theory, speaks volumes to
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`the merits of the petition.
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`(2) to explain why Petitioner’s new claim construction position on
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`“identification signal” was incorrect and why Dr. Baker’s opinion in the district
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`court supports Patent Owner’s position and not Petitioner’s position. Sur-reply at
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`13; see also EX2030-p.231 n.3; EX2025, 204:5-208:25 (questions directed to the
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`opinions expressed by Dr. Baker in EX2030-p.231 n.3 and EX1026, ¶ 32). As
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`explained above in Section II.B, the Board should be made aware of such
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`inconsistent positions. 37 C.F.R. § 42.51(b)(1)(iii).5
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`As also noted above, Petitioners do not assert that they have suffered any
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`prejudice for either citation. Mtn. 1-2. Nor do they object to the substance of the
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`arguments associated with the citations to EX2030. Id. Indeed, they even tacitly
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`acknowledge that evidence other than transcripts can accompany a sur-reply by not
`
`objecting to either EX2026 (errata to EX1021) or EX2031 (a drawing created by
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`Dr. Baker during his deposition and thus a part of the transcript). See Section I.C.
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`EX2030 is similar in nature to EX2026 and EX2031. Like EX2026 and EX2031,
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`5 As noted above, the reference to EX2030 on page 30 of Paper 24 appears
`
`in the certificate of service. The sur-reply ends on page 28.
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`EX2030 also did not exist when the POR was due and therefore Patent Owner
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`could not have filed it earlier. And like EX2026 and EX2031, EX2030 also did not
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`include content that was/is of surprise to Petitioners: EX2026 corrected
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`transcription errors for a deposition taken by Petitioners’ counsel, EX2031 was
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`created by Dr. Baker to aid his testimony, and EX2030 was supposedly authored
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`by Dr. Baker. Inclusion of EX2030 is thus just as proper as for EX2026 and
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`EX2031, in that they all facilitate maintaining a complete and correct record of the
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`proceeding, including the deposition that took place on April 4, 2022.
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`In sum, because EX2030 was introduced to fresh Dr. Baker’s memory,
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`because there is indisputably no prejudice to Petitioners, and because a motion to
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`strike “is an exceptional remedy” that should “be granted rarely” (TPG at 81),
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`Petitioner’s motion should be denied and EX2030 should be retained as part of the
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`record in the interests of justice.
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`
`Dated: May 16, 2022
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`
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`
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`Respectfully submitted,
`
`/Hong Zhong/
`H. Annita Zhong (Reg. No. 66,530)
`Irell & Manella LLP
`1800 Avenue of the Stars, Suite 900
`Los Angeles, CA 90067
`Tel: (310) 277-1010
`Email: HZhong@irell.com
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`Case IPR2021-00599
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`CERTIFICATE OF SERVICE
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`I hereby certify, pursuant to 37 C.F.R. section 42.6, that on May 16, 2022, a
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`complete copy of the foregoing document was served upon the following, by
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`ELECTRONIC MAIL:
`
` ORRICK, HERRINGTON & SUTCLIFFE, LLP
`
` Jeffrey Johnson, Reg. No. 53,078
`3J6PTABDocket@orrick.com
`
`
`Robert J. Benson
`R75PTABDocket@orrick.com
`
`
`Jeremy Jason Lang
`PTABDocketJJL2@Orrick.com
`
`TCL-FISI_OHS@orrick.com
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` /Susan M. Langworthy/
` Susan M. Langworthy
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