UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`APPLE INC.,
`Petitioner
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`v.
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`GUI GLOBAL PRODUCTS, LTD.,
`Patent Owner
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`Case IPR2021-01289
`Patent 10,259,020
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`PETITIONER’S CONDITIONAL MOTION FOR JOINDER
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`APPLE INC.,
`Petitioner
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`v.
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`GUI GLOBAL PRODUCTS, LTD.,
`Patent Owner
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`Case IPR2021-01289
`Patent 10,259,020
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`PETITIONER’S CONDITIONAL MOTION FOR JOINDER
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`I.
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`Atty. Dkt. 50095-0028IP2
`U.S. Patent No. 10,259,020
`STATEMENT OF PRECISE RELIEF REQUESTED
`Pursuant to 35 U.S.C. § 315(c) and 37 C.F.R. § 42.122(b), Apple Inc.
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`(“Apple” or “Petitioner”) conditionally moves for joinder with the inter partes
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`review instituted against U.S. Patent No. 10,259,020 (“the ’020 Patent”) in Samsung,
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`et al., v. GUI Global Products, Ltd., IPR2021-00335 (“the 335 Proceeding”). This
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`motion is timely filed within one month of the Board’s July 2, 2021 institution
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`decision in the 335 Proceeding.
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`More specifically, Apple respectfully requests that the Board institute review
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`of IPR2021-01289 based on the concurrently-filed petition and that it grant this
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`motion if, and only if, the Board has previously denied institution of Apple Inc., v.
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`GUI Global Products, Ltd., IPR2021-00470 (“the 470 Proceeding”). In making this
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`request, Apple seeks to ensure that, for each of the four patents that GUI presently
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`asserts against Apple and Samsung, Apple is party to one (and only one) instituted
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`inter partes review proceeding, preferably the proceeding inspired by Apple’s initial
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`filing but otherwise the proceeding inspired by Samsung’s first filing.1 In this way,
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`consistent with the goals expressed in each of the Board’s NHK, Fintiv, Snap, Sotera,
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`General Plastic, and Uniloc decisions, Apple seeks to promote a maximally-efficient
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`1 Apple is concurrently filing conditional motions for joinder with respect to each of
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`the IPR2021-01290, IPR2021-01291, and IPR2021-01292 petitions.
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`1
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`Atty. Dkt. 50095-0028IP2
`U.S. Patent No. 10,259,020
`resolution to the dispute between the parties. See, e.g., General Plastic Indus. Co.
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`v. Cannon Kabushiki Kaisha, IPR2016-01357, Pap. 19 at 16 (PTAB Sept. 6,
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`2017)(precedential)(“In exercising discretion…we are mindful of the goals of the
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`AIA–namely, to improve patent quality and make the patent system more efficient
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`by the use of post-grant review procedures”); Apple Inc. v. Fintiv, Inc., IPR2020-
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`00019, Pap. 11 at 6 (PTAB Mar. 20, 2020)(“the Board takes a holistic view of
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`whether efficiency and integrity of the system are best served by denying or
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`instituting review”).
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`The parties to the counterpart consolidated district court litigation have
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`already agreed that, if “all four of Apple’s IPR petitions are instituted”2 then
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`“Plaintiff would not oppose a motion…by Samsung and Apple to stay the
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`[counterpart] litigation pending final decisions from the PTAB in all then-
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`pending…IPRs.” EX1116, 2 (emphasis added). Conversely, GUI has indicated that
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`it would oppose a motion to stay the counterpart litigation if any of Apple’s
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`IPR2021-00470, IPR2021-00471, IPR2021-00472, and IPR2021-00473 petitions
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`are not instituted. Id.; see also EX1115, 1.
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`2 Referring to Apple’s IPR2021-00470, IPR2021-00471, IPR2021-00472, and
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`IPR2021-00473 petitions, on which institution decisions remain pending.
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`2
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`Atty. Dkt. 50095-0028IP2
`U.S. Patent No. 10,259,020
`Thus, if all four of Apple’s IPR petitions are instituted, Apple’s and
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`Samsung’s printed publication invalidity grounds would likely be addressed by a
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`single forum—the PTAB. This is the maximally efficient outcome, and the outcome
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`that Apple seeks to promote via this conditional motion for joinder. Cf. Snap, Inc.
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`v. SRK Technology LLC, IPR2020-00820 Pap. 15 at 9, 19 (PTAB Oct. 21,
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`2020)(precedential); Sotera Wireless, Inc. v. Masimo Corp., IPR2020-01019 Pap. 12
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`at 19-21 (PTAB Dec. 1, 2020)(precedential).
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`However, if the Board were to decline to institute Apple’s IPR2021-00470
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`petition challenging the ’020 Patent, the next-most efficient course of action would
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`be for the Board to institute review of IPR2021-01289 and grant this motion for
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`joinder with Samsung’s already-instituted 335 Proceeding. Indeed, the district
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`court’s Amended Scheduling Order (entered July 16, 2021) contemplates that “if all
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`of Apple’s IPR Petitions are not instituted,” the parties will brief an opposed motion
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`to stay. EX1115. As to this less preferred alternative, where Apple is joined to the
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`335 Proceeding in an understudy role, it remains likely that the district court would
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`grant a motion for stay, even if opposed by GUI. The consolidated nature of the
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`counterpart district court litigation combined with the fact that all four of Samsung’s
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`IPR proceedings have already been instituted heavily favors a stay.3 See EX1102;
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`3 The Board instituted each of IPR2021-00335, IPR2021-00336, IPR2021-00337,
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`3
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`Atty. Dkt. 50095-0028IP2
`U.S. Patent No. 10,259,020
`EX1103; EX1104; Memorandum and Order granting motion to stay in Fairfield
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`Industries Inc. v. Seabed Geosolutions (US) Inc., Case H-17-cv-1458 (S.D. Tex. Jan.
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`2019) at 3 (“A stay of patent litigation is ‘particularly justified when the outcome of
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`a PTO proceeding is likely to assist the court in determining patent validity or
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`eliminate the need to try infringement issues.’”); Memorandum and Order in
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`Onesubsea IP US Ltd. v. FMC Technologies, Inc., Case H-16-cv-0051 (S.D. Tex.
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`Aug. 2016) at 4 (“The Court finds that a stay of this case pending the completion of
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`the IPR process will provide the Court and the parties with potentially important
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`guidance from the patent office, will simplify the case, will avoid a needless waste
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`of resources, and will prevent inconsistent results between the IPR proceedings and
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`this lawsuit”).
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`Thus, while a grant of Apple’s first-filed petitions would maximize the
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`likelihood of the parties avoiding the unnecessary costs of duplicative litigation in
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`different forums on the subject of validity over the same prior art grounds, and
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`decrease the likelihood of potentially inconsistent decisions from different forums
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`addressing those grounds, the grant of this conditional motion for joinder also would
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`increase the likelihood (albeit to a lesser extent) of achieving similar goals.
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`and IPR2021-00338 on July 2, 2021.
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`4
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`Atty. Dkt. 50095-0028IP2
`U.S. Patent No. 10,259,020
`On the other hand, if the Board were to deny both of Apple’s petitions against
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`the ’020 Patent (IPR2021-00470 and IPR2021-01289), Apple would have no choice
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`but to pursue its printed publication invalidity defenses in district court, separate and
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`apart from the already-instituted 335 Proceeding.
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`Against that outcome, institution of one petition or the other in the alternative
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`would very likely confine adjudication of invalidity grounds based on printed
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`publication prior art to the PTAB4, and would also very likely result in a stay of the
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`district court litigation. EX1115, EX1116. The present circumstances therefore
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`offer a prime opportunity for IPR to serve its intended role as a true alternative to
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`district court litigation. See Snap at 9, 19; Sotera at 19-21.
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`Even beyond that point, the circumstances of the instant petition and
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`conditional motion for joinder are materially distinct from those addressed by the
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`Board’s Uniloc decision. In that decision, the petitioner was said to have “failed in
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`its first attempt to challenge the [subject] patent,” and the subsequent attempt to “join
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`an ongoing proceeding challenging the same patent” was said to have been made
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`“over a year later and subject to a § 315(b) bar ….” Apple Inc. v. Uniloc 2017 LLC,
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`4 The district court has yet to set a trial date, and there is no reasonable expectation
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`that it will schedule a trial ahead of the Board’s FWD in IPR2021-00335 (even
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`assuming that the district court does not stay).
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`5
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`Atty. Dkt. 50095-0028IP2
`U.S. Patent No. 10,259,020
`IPR2020-00854 Pap. 9 at 7 (PTAB Oct. 28. 2020)(precedential).
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`Unlike Uniloc, the Board has yet to issue an institution decision with respect
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`to Apple’s 470 Proceeding, and thus, Apple has not had any opportunity to take
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`advantage of such a decision. Further, the instant petition to which this motion
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`pertains is not time-barred.5 And, as explained in more detail in the petition itself,
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`the General Plastic factors favor institution.
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`Moreover, and as explained in more detail below, joinder as sought in the
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`specific circumstances on which this conditional motion is premised would help to
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`efficiently resolve the disputes among the parties, without unduly prejudicing any
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`party. Accordingly, if the Board were to deny instution of Apple’s 470 Proceeding
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`challenging the ’020 Patent, Apple respectfully submits that it should be allowed to
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`join Samsung’s 335 Proceeding in an “understudy” role. See Dell Inc. v. Network-
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`1 Sec. Solutions, Inc., IPR2013-00385, Paper 17 at 4-6 (PTAB Jul. 29 2013).
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`5 GUI’s complaint alleging infringement of the ’020 Patent was served on Apple on
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`July 30, 2020. EX1100; EX1118.
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`6
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`Atty. Dkt. 50095-0028IP2
`U.S. Patent No. 10,259,020
`II. BACKGROUND AND RELATED PROCEEDINGS
`GUI Global Products, Ltd. is the purported owner of the ’020 Patent. GUI
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`asserted the ’020 Patent (and related patents US 10,562,077, US 10,259,021, and US
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`10,589,320) against each of Apple and Samsung in two separate actions that have
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`since been consolidated: Civil Action No. 4:20-cv-2652 (SDTX) and Civil Action
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`No. 4:20-cv-2624 (SDTX).
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`Apple is filing the instant petition addressing the ’020 patent (“Petition”)
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`concurrently with three additional petitions corresponding to each of the three other
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`patents that GUI presently asserts against Apple and Samsung (IPR2021-01290,
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`IPR2021-01291, and IPR2021-01292).
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`The table below summarizes the pre-existing inter partes review proceedings.
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`Patent
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`IPR Proceedings
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`US 10,589,320 Samsung: IPR2021-00338 (instituted July 2, 2021)
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`Apple: IPR2021-00473 (institution decision due August 19, 2021)
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`US 10,562,077 Samsung: IPR2021-00337 (instituted July 2, 2021)
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`Apple: IPR2021-00472 (institution decision due August 19, 2021)
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`US 10,259,021 Samsung: IPR2021-00336 (instituted July 2, 2021)
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`Apple: IPR2021-00471 (institution decision due August 19, 2021)
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`US 10,259,020 Samsung: IPR2021-00335 (instituted July 2, 2021)
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`Apple: IPR2021-00470 (institution decision due August 19, 2021)
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`7
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`Atty. Dkt. 50095-0028IP2
`U.S. Patent No. 10,259,020
`III. STATEMENT OF REASONS FOR THE RELIEF REQUESTED
`The Board has discretion to join a properly filed IPR petition to an existing
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`IPR proceeding. See 35 U.S.C. § 315(c); 37 C.F.R. § 42.122(b); see also Dell Inc.
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`v. Network-1 Sec. Solutions, Inc., IPR2013-00385, Pap. 17 at 4-6 (PTAB Jul. 29
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`2013); Sony Corp. v. Yissum Res. & Dev. Co. of the Hebrew Univ. of Jerusalem,
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`IPR2013- 00326, Pap. 15 at 3-4 (PTAB Sep. 24, 2013); Microsoft Corp. v.
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`Proxyconn, Inc., IPR2013-00109, Pap. 15 at 3-4 (PTAB Feb. 25, 2013). “The Board
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`will determine whether to grant joinder on a case-by-case basis, taking into account
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`the particular facts of each case, substantive and procedural issues, and other
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`considerations.” Dell at 3. The movants bear the burden of proof in establishing
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`entitlement to the requested relief. 37 §§ 42.20(c), 42.122(b). A motion for joinder
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`should:
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`[A] set forth the reasons why joinder is appropriate; [B] identify any
`new grounds of unpatentability asserted in the petition; [C] explain
`what impact (if any) joinder would have on the trial schedule for the
`existing review; and [D] address specifically how briefing and
`discovery may be simplified.
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`Dell at 4.
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`A.
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`Joinder with the 335 Proceeding Would be Appropriate
`If the Board were to deny instution of Apple’s 470 Proceeding challenging
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`the ’020 Patent, Apple respectfully requests institution of the petition for inter partes
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`8
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`Atty. Dkt. 50095-0028IP2
`U.S. Patent No. 10,259,020
`review filed concurrently herewith (“Petition”), and respectfully submits that joinder
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`with the 335 Proceeding would be appropriate. The Petition is materially the same
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`as the petition filed in the 335 Proceeding. The Petition and the petition in the 335
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`Proceeding challenge the same claims, on the same grounds and rely on the same
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`prior art and evidence, including an identical declaration from the same expert.6
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`Further, Apple agrees to proceed solely on the grounds, evidence, and
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`arguments advanced, or that will be advanced, in the 335 Proceeding as instituted.
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`The Petition therefore warrants institution under 35 U.S.C. § 314, and 35 U.S.C. §
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`315(c) permits Apple’s joinder to the inter partes review instituted in the 335
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`Proceeding.
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`Further, upon joining the 335 Proceeding, Apple will act as an “understudy”
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`and will not assume an active role unless the current petitioner (Samsung) ceases to
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`participate in the 335 Proceeding. The current petitioner will maintain the lead role
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`in the proceeding so long as the current petitioner remains in the proceeding. These
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`limitations will avoid lengthy and duplicative briefing. Apple also will not seek
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`additional depositions or deposition time. Apple further agrees to the foregoing
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`conditions even in the event that other third-party petitioners are joined with the 335
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`Proceeding. Accordingly, the proposed joinder will neither unduly complicate the
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`6 The declaration is an exact duplicate of the declaration in the 335 Proceeding.
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`9
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`Atty. Dkt. 50095-0028IP2
`U.S. Patent No. 10,259,020
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`335 Proceeding nor delay its schedule.
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`In fact, joinder will help efficiently resolve the disputes among the parties. By
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`joinder, a single Board decision may dispose of the issues raised in the 335
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`Proceeding for all interested parties. Further, joinder will narrow the issues in the
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`co-pending district court actions because Petitioner and the current petitioner in the
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`335 Proceeding have each, contingent upon institution, stipulated to forego raising
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`the grounds of unpatentability in the 335 Proceeding at the district court. Further
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`still, because the District Court has yet to set a trial date, joinder would almost
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`certainly result in a final written decision that prevents (via the 315(e)(2) estoppel)
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`both Apple and the current petitioner in the 335 Proceeding from pursuing printed
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`publication invalidity grounds at trial in the District Court. Finally, joinder would
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`not complicate or delay the 335 Proceeding, and would not adversely affect any
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`schedule set in that proceeding. In sum, joinder would promote efficient
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`adjudication in multiple forums.
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`Further, joinder will not unduly prejudice any party. Because joinder will not
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`add any new substantive issues, delay the schedule, burden deponents, or increase
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`needless filings, any additional costs on the Patent Owner would be minimal. On
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`the other hand, denial of joinder would prejudice Apple. Apple’s interests may not
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`be adequately protected in the 335 Proceeding, particularly if the current petitioner
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`(Samsung) settles with the Patent Owner.
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`10
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`Atty. Dkt. 50095-0028IP2
`U.S. Patent No. 10,259,020
`The Board “routinely grants motions for joinder where the party seeking
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`joinder introduces identical arguments and the same grounds raised in the existing
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`proceeding.” Samsung Elecs. Co., Ltd. v. Raytheon Co., IPR2016-00962, Paper No.
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`12 at 9 (Aug. 24, 2016) (emphasis added) (internal quotations and citations omitted).
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`Here, joinder with the 335 Proceeding is appropriate because the Petition introduces
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`identical unpatentability arguments and the same grounds raised in the petition of
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`the 335 Proceeding, without any change to the facts, citations, evidence, or
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`arguments used in demonstrating satisfaction of the implicated claims by the applied
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`prior art. Because these proceedings introduce identical unpatentability arguments
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`and the same grounds, good cause exists for joinder, so that the Board, consistent
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`with 37 C.F.R. § 42.1(b), can efficiently “secure the just, speedy, and inexpensive
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`resolution” of this proceeding and the 335 Proceeding.
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`B.
`Joinder Would Not Add Any New Grounds of Unpatentability
`The Petition is based on the same grounds and combinations of prior art in the
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`335 Proceeding. For simplicity and efficiency, Petitioner has copied the substance
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`of the petition in the 335 Proceeding and its accompanying expert declaration.
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`Petitioner does not seek to introduce grounds or claims not currently in the 335
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`Proceeding and seeks only to join the proceeding as instituted. Patent Owner should
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`not require any discovery beyond that which it may need in the 335 Proceeding—
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`nor should the Board permit any. The present Petition introduces no new substantive
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`11
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`Atty. Dkt. 50095-0028IP2
`U.S. Patent No. 10,259,020
`issues relative to the 335 Proceeding and does not seek to broaden the scope of the
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`335 Proceeding.
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`C.
`Joinder Would Not Impact the 335 Proceeding’s Trial Schedule
`Joinder will not impact the 335 proceeding trial schedule because the present
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`Petition presents no new issues or grounds of unpatentability. See Sony Corp., et al.
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`v. Memory Integrity, LLC, IPR2015-01353, Paper No. 11 at 6 (granting IPR and
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`motion for joinder where “joinder should not necessitate any additional briefing or
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`discovery from Patent Owner beyond that already required in [the original IPR]”).
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`Further, Petitioner explicitly consents to the trial schedule as adopted in the 335
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`proceeding. There are no new issues for the Board to address, and Patent Owner
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`will not be required to present any additional responses or arguments.
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`The Patent Owner’s Response will also not be negatively impacted because
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`the substantive issues presented in the present Petition are identical to the issues
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`presented in the 335 Proceeding. Patent Owner will not be required to provide any
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`additional analysis or arguments beyond what it will already provide in responding
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`to the petition in the 335 Proceeding. Also, because the present Petition relies on
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`the same expert declaration, only a single deposition is needed for the proposed
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`joined proceeding.
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`Accordingly, joinder with the 335 Proceeding does not unduly burden or
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`negatively impact the trial schedule.
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`12
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`Atty. Dkt. 50095-0028IP2
`U.S. Patent No. 10,259,020
`D.
`Procedures to Simplify Briefing and Discovery
`Apple explicitly agrees to take an “understudy” role, which will simplify
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`briefing and discovery. Specifically, Apple explicitly agrees, upon joining the 335
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`Proceeding, that the following conditions, as previously approved by the Board in
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`similar circumstances, shall apply so long as the current petitioner remains an active
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`party:
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`a) all filings by Petitioner in the 335 Proceeding shall be consolidated with
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`the filings of the current petitioner, unless a filing concerns issues solely
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`involving Petitioner;
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`b) Petitioner shall not be permitted to raise any new grounds not instituted
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`by the Board in the 335 Proceeding, or introduce any argument or
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`discovery not introduced by the current petitioner;
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`c) Petitioner shall be bound by any agreement between Patent Owner and
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`the current Petitioner concerning discovery and/or depositions; and
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`d) Petitioner at deposition shall not receive any direct, cross examination
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`or redirect time beyond that permitted under either 37 C.F.R. § 42.53
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`or any agreement between Patent Owner and the current petitioner.
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`See Noven Pharmaceuticals, Inc. v. Novartis AG, IPR2014-00550, Paper No. 38 at
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`5 (Apr. 10, 2015). Unless and until the current petitioner ceases to participate, Apple
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`will not assume an active role in the 335 Proceeding.
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`13
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`Atty. Dkt. 50095-0028IP2
`U.S. Patent No. 10,259,020
`Thus, by Apple accepting an “understudy” role, the parties can comply with
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`the trial schedule assigned to the 335 Proceeding without needing any duplicative
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`efforts by the Board or the Patent Owner. These steps minimize the possibility of
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`any complication or delay from joinder. See Sony, IPR2015-01353, Paper No. 11 at
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`6-7 (granting IPR and motion for joinder because “joinder would increase efficiency
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`by eliminating duplicative filings and discovery, and would reduce costs and burdens
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`on the parties as well as the Board” where petitioners agreed to an “understudy”
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`role). Apple is further willing to agree to any other reasonable conditions the Board
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`deems necessary.
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`IV. CONCLUSION
`For the foregoing reasons, Apple respectfully requests that if, and only if, the
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`Board has previously denied institution of the 470 Proceeding, the Board institute
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`review of IPR2021-01289 and grant this motion for joinder with IPR2021-00335.
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`Dated July 30, 2021
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`(Control No. IPR2021-01289)
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`Respectfully submitted,
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` /Andrew B. Patrick/
`W. Karl Renner, Reg. No. 41,265
`Andrew B. Patrick, Reg. No. 63,471
`Roberto Devoto, Reg. No. 55,108
`Kenneth Wayne Darby Jr., Reg. No. 65,068
`Kim Leung, Reg. No. 64,399
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`
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` Attorneys for Petitioner
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`14
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`CERTIFICATE OF SERVICE
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`Atty. Dkt. 50095-0028IP2
`U.S. Patent No. 10,259,020
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`Pursuant to 37 CFR § 42.6(e), the undersigned certifies that on July 30, 2021,
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`a complete and entire copy of this Motion for Joinder was provided via email to the
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`Petitioner by serving the correspondence email addresses of record as follows:
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`Mossman, Kumar & Tyler PC
`P.O. Box 421239
`Houston TX 77242
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`/Crena Pacheco/
`Crena Pacheco
`Fish & Richardson P.C.
`60 South Sixth Street, Suite 3200
`Minneapolis, MN 55402
`(202) 626-6420
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