UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`APPLIED MATERIALS, INC.,
`Petitioner
`
`v.
`
`OCEAN SEMICONDUCTOR LLC,
`Patent Owner
`
`IPR2021-01342
`Patent No. 6,968,248
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`PATENT OWNER’S OPPOSITION TO PETITIONER’S MOTION TO
`STRIKE
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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
`Submitted Electronically via PTAB E2E
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`

`

`Table of Contents
`INTRODUCTION .......................................................................................... 1
`
`I.
`
`II. PETITIONER REFUSED TO MEET AND CONFER WITH PATENT
`OWNER ON PETITIONER’S MOTION .............................................................. 1
`
`III. PETITIONER’S REPLY INCLUDED NEW ARGUMENT ON THE
`“INTEGRATED, AUTOMATED PROCESS FLOW” OF CLAIMS 1 AND 14 ... 4
`
`IV. PETITIONER, NOT PATENT OWNER, RAISED ISSUES OF CLAIM
`CONSTRUCTION IN THIS PROCEEDING ........................................................ 5
`
`V. PATENT OWNER’S CITATION OF THE ’248 SPECIFICATION WAS
`WITHIN THE PERMISSIBLE SCOPE OF A SUR-REPLY ................................. 8
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`VI. THERE IS NO PREJUDICE TO PETITIONER ............................................. 9
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`VII. CONCLUSION ..............................................................................................10
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`
`i
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`

`

`
`
`Table of Authorities
`
`Apple, Inc. v. Uniloc 2017 LLC,
`IPR2019-00918, Paper 21 (P.T.A.B. Oct. 15, 2020) .......................................... 8
`
`Idemitsu Kosan Co. v. SFC Co.,
`870 F.3d 1376, 1381 (Fed. Cir. 2017) ................................................................10
`
`In re Morsa,
`713 F.3d 104, 110 (Fed. Cir. 2013) ..................................................................... 4
`
`ii
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`

`

`
`
`LIST OF EXHIBITS RELIED ON
`
`Description
`Exhibit
`2001 Ocean Semiconductor LLC v. MediaTek Inc., et al., No. 6:20-cv-1210-
`ADA, D.I. 32, Scheduling Order
`2002 Ocean Semiconductor LLC v. NVIDIA Corporation, No. 6:20-cv-1211-
`ADA, D.I. 32, Scheduling Order
`2003 Ocean Semiconductor LLC v. NXP USA, Inc., No. 6:20-cv-1212-ADA,
`D.I. 34, Scheduling Order
`2004 Ocean Semiconductor LLC v. Renesas Electronics Corp. et al., No.
`6:20-cv-1213-ADA, D.I. 43, Scheduling Order
`2005 Ocean Semiconductor LLC v. Silicon Labs Inc., No. 6:20-cv-1214-
`ADA, D.I. 31, Scheduling Order
`2006 Ocean Semiconductor LLC v. STMicroelectronics Inc., No. 6:20-cv-
`1250-ADA, D.I. 34, Scheduling Order
`2007 Ocean Semiconductor LLC v. Western Digital Techs Inc., No. 6:20-cv-
`1216-ADA, D.I. 34, Scheduling Order
`2008 Ocean Semiconductor LLC v. Huawei Device USA Inc., No. 4:20-cv-
`991-ALM, D.I. 22, Scheduling Order
`2009 Ocean Semiconductor LLC v. Western Digital Techs Inc., No. 6:20-cv-
`1216-ADA, D.I. 1, Complaint
`2010 Ocean Semiconductor LLC v. STMicroelectronics Inc., No. 6:20-cv-
`1250-ADA, D.I. 1, Complaint
`2011 Ocean Semiconductor LLC v. Silicon Labs Inc., No. 6:20-cv-1214-
`ADA, D.I. 1, Complaint
`2012 Ocean Semiconductor LLC v. Renesas Electronics Corp. et al., No.
`6:20-cv-1213-ADA, D.I. 1, Complaint
`2013 Ocean Semiconductor LLC v. NXP USA, Inc., No. 6:20-cv-1212-ADA,
`D.I. 1, Complaint
`2014 Ocean Semiconductor LLC v. NVIDIA Corporation, No. 6:20-cv-1211-
`ADA, D.I. 1, Complaint
`2015 Ocean Semiconductor LLC v. MediaTek Inc., et al., No. 6:20-cv-1210-
`ADA, D.I. 1, Complaint
`2016 Ocean Semiconductor LLC v. Huawei Device USA Inc., No. 4:20-cv-
`991-ALM, D.I. 1, Complaint
`2017 Ocean Semiconductor LLC v. Huawei Device USA Inc., No. 4:20-cv-
`991-ALM, D.I. 27, Order
`2018 Ocean Semiconductor LLC v. MediaTek Inc., et al., No. 6:20-cv-1210-
`ADA, Notice of Electronic Filing, D.I. 20
`
`iii
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`

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`2019 Ocean Semiconductor LLC v. Huawei Device USA Inc., No. 4:20-cv-
`991-ALM, D.I. 17, Memorandum Opinion and Order
`2020 Ocean Semiconductor LLC v. NVIDIA Corporation, No. 6:20-cv-1211-
`ADA, Notice of Electronic Filing (Text Order)
`2021 Ocean Semiconductor LLC v. Renesas Electronics Corp. et al., No.
`6:20-cv-1213-ADA, Notice of Electronic Filing, D.I. 46
`2022 Ocean Semiconductor LLC v. NVIDIA Corporation, No. 6:20-cv-1211-
`ADA, Notice of Electronic Filing, D.I. 37
`2023 Ocean Semiconductor LLC v. Renesas Electronics Corp. et al., No.
`6:20-cv-1213-ADA, D.I. 15, Rule 12(b)(6) Motion to Dismiss
`2024 Exhibit D-4 to Defendants’ Preliminary Invalidity Contentions
`2025 Exhibit D-9 to Defendants’ Preliminary Invalidity Contentions
`2026 Ryan Davis, How Texas Judges Have Kept IP Trials Moving During
`COVID, LAW360, Apr. 6, 2021, https://www.law360.com/
`articles/1372773/how-texas-judges-have-kept-ip-trials-movingduring-
`covid
`2027 Exhibit D-4 to Defendants’ Invalidity Contentions
`2028 Exhibit D-9 to Defendants’ Invalidity Contentions
`2029 Defendants’ Preliminary Invalidity Contentions
`2030 Defendants’ Invalidity Contentions
`2031 Ocean Semiconductor LLC v. NXP USA Inc., No. 6:20-cv-1212-ADA,
`D.I. 28, Opposition to Mtn for Consolidation
`2032 Ocean Semiconductor LLC v. STMicroelectronics Inc., No. 6:20-cv-
`1215-ADA, D.I. 28, Opposition to Mtn for Consolidation
`2033 Ocean Semiconductor LLC v. Silicon Labs Inc., No. 6:20-cv-1214-
`ADA, D.I. 25, Opposition to Mtn for Consolidation
`2034 Ocean Semiconductor LLC v. MediaTek Inc., et al., No. 6:20-cv-1210-
`ADA, D.I. 25, Opposition to Mtn for Consolidation
`2035 Ocean Semiconductor LLC v. Renesas Electronics Corp. et al., No.
`6:20-cv-1213-ADA, D.I. 29, Opposition to Mtn for Consolidation
`Standard Scheduling Order, United States District Court for the
`Eastern District of Texas
`2037 Lauren Berg, Google Hit With $26M Video Patent Verdict In WDTX,
`LAW360, Nov. 16, 2021, https://www.law360.com/articles/1441219
`2038 Ocean Semiconductor LLC v. Analog Devices, Inc., No. 20-12310-PBS,
`D.I. 37, Order Allowing Stay
`2039 Ocean Semiconductor LLC v. Infineon Technologies AG et al., No. 20-
`12311-PBS, D.I. 38, Order Allowing Stay
`
`2036
`
`iv
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`

`

`2040 Ocean Semiconductor LLC v. MediaTek Inc., et al., No. 6:20-cv-1210-
`ADA, D.I. 51, Claim Construction Order
`2041 Declaration of Kurt D. Humphrey
`2042 Kurt D. Humphrey C.V.
`2043 Declaration of Peter A. Mazur In Support of
`Patent Owner’s Motion for Pro Hac Vice Admission
`2044 Rough Transcript of the Deposition of Dr. Stanley Shanfield, August
`29, 2022
`2045 CONFIDENTIAL Release Agreement
`2046
`September 15, 2022 Email Exchange between Petitioner and Patent
`Owner
`
`v
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`

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`I.
`
`INTRODUCTION
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`It is Petitioner who raised new arguments in its Reply, which required a
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`response from Patent Owner in the Sur-Reply. As noted in Patent Owner’s Amended
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`Sur-Reply, Petitioner’s Reply is replete with new matter entirely absent from the
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`Petition and to which Patent Owner was never given a fair opportunity to respond in
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`either its Patent Owner’s Preliminary Response (“POPR”) or its Patent Owner’s
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`Response (“POR”). (See Paper 41 (“Sur-Reply”) at 1, 4, 8-9.) Petitioner now
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`compounds this circumvention of the procedural rules for inter partes review with a
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`Motion to Strike Patent Owner’s arguments in response. (Paper 46 (“Mot.”)).
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`As shown below, each portion of the Sur-Reply that Petitioner asks the Board
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`to strike directly responds to arguments and evidence presented by Petitioner in its
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`Reply, in most cases for the first time. As such, granting Petitioner’s Motion as to
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`any of the cited portions of the Sur-Reply would serve no purpose other than to
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`reward Petitioner’s abuse of the Board’s procedures and deprive Patent Owner of an
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`opportunity to fully respond to Petitioner’s arguments.
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`In addition, Petitioner did not properly meet and confer with Patent Owner
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`before filing, the Motion to Strike, in violation of the Board’s procedures.
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`II.
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`PETITIONER REFUSED TO MEET AND CONFER WITH PATENT
`OWNER ON PETITIONER’S MOTION
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`Petitioner has failed to satisfy—or even make a good faith attempt to satisfy—
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`the meet and confer requirement with respect to the issues in the present Motion, and
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`1
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`

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`the Motion should be denied. The Patent Trial and Appeal Board Consolidated Trial
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`Practice Guide (“TPG”) is clear—prior to seeking leave to file a motion such as the
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`one at issue herein, Petitioner was required to meet and confer with Patent Owner.
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`Office Patent Trial Practice Guide, 84 FR 64280, at 9 (Nov. 21, 2019) (“Prior to
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`making a request for a conference call, the parties should meet and confer to resolve
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`any disputes.”). Petitioner has failed to do so.
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`Petitioner’s only attempt to raise such issue with Patent Owner came in a
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`September 15, 2022, email to Patent Owner stating that Petitioner believed certain
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`sections of Patent Owner’s Sur-Reply raised new arguments. (See Ex. 2046 at 2-3.)
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`Patent Owner responded the same day, requesting additional information so that it
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`could provide a fully informed position statement on Petitioner’s proposed motion
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`to strike. (Id. at 2.) At 10 PM E.T. the same day, Petitioner refused to offer the
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`requested information and emailed the Board its request to file a motion to strike the
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`following morning without waiting even one business day for Patent Owner’s
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`response. (Id. at 1.)
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`Petitioner’s single email to Patent Owner did not satisfy the meet and confer
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`requirement of the TPG. Not only did Petitioner refuse to offer the arguments it now
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`raises in its Motion to Strike, Petitioner did not even inform Patent Owner that it
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`sought to strike evidence as well. (Id. at 2 (“Petitioner Applied Materials plans to
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`request the Board for authorization to file motions to strike the following portions of
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`2
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`

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`Ocean’s sur‐replies, or in the alternative for further merits briefing to address the
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`newly‐raised arguments.”).)1 Petitioner not only refused to offer any reasoning for
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`its assertions, but it failed even to inform Patent Owner of the extent of the relief it
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`sought. Patent Owner cannot be expected to offer a position statement on an issue
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`which has not been raised by Petitioner.
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`This is not the first time Petitioner has failed to satisfy the Board’s meet and
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`confer requirements. For example, with regard to Petitioner’s objection to Patent
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`Owner taking the deposition of Petitioner’s expert, Petitioner failed to raise relevant
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`case law with Patent Owner during previous meet and confers. Petitioner only
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`presented the case law during a conference call with the Board, leaving both the
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`Board and Patent Owner unprepared to discuss Petitioner’s objections.
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`Petitioner’s repeated failure to meet and confer with Patent Owner has caused
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`miscommunications and prejudiced Patent Owner while simultaneously wasting the
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`Board’s limited resources. If left unchecked, Petitioner’s continued disregard for
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`procedure will only cause further prejudice and waste further judicial resources.
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`Petitioner cannot be permitted to casually flaunt the Board’s regulations and
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`procedures. Patent Owner therefore respectfully asks that the Board deny the present
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`Motion to Strike without prejudice and, as the TPG contemplates, order the Parties
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`to confer on the present issues.
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`1 Unless noted otherwise, all emphasis in this Opposition is added.
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`3
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`

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`III. PETITIONER’S REPLY INCLUDED NEW ARGUMENT ON THE
`“INTEGRATED, AUTOMATED PROCESS FLOW” OF CLAIMS 1
`AND 14
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`Not a single one of paragraphs [0005], [0006], [0008]-[0010], [0012], [0056]
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`and [0064] of Schulze, which Petitioner identifies in its Reply (at 8) as disclosing
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`the “integrated, automated process flow” of claims 1 and 14, is identified in the
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`Petition in connection with this claim element, and most were never cited at all.
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`Despite the fact that these citations were available to Petitioner at the time of the
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`Petition, it waited until the last moment to argue that they are relevant to the
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`“integrated, automated process flow,” leaving the Sur-Reply as Patent Owner’s sole
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`opportunity to respond.
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`In light of its failure to include these disclosures in the Petition, Petitioner’s
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`argument that its prior art references are presumed to be enabling (Mot. at 4) is
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`unsupported. Moreover, it is well-established that prior art references which are not
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`enabling on their face are not entitled to an enablement presumption. See In re
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`Morsa, 713 F.3d 104, 110 (Fed. Cir. 2013). (“Where a reference appears to not be
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`enabling on its face, however, an applicant may successfully challenge the cited prior
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`art for lack of enablement by argument without supporting evidence.”). Thus, even
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`to the extent that the Board finds that the presumption would apply, it would be
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`unfair to strike Patent Owner’s enablement arguments on that basis alone.
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`4
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`

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`IV. PETITIONER, NOT PATENT OWNER, RAISED ISSUES OF CLAIM
`CONSTRUCTION IN THIS PROCEEDING
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`Petitioner’s Motion to Strike ignores entirely the fact that Petitioner is the only
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`party that has raised issues of claim construction in this proceeding. After submitting
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`the WDTX and EDTX claim construction orders into the record for the first time in
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`Petitioner’s Reply, and adopting claim construction positions that track those orders
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`(Reply at 11-15), Petitioner now suggests that the Board strike portions of Patent
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`Owner’s Sur-Reply which are merely responsive to Petitioner’s claim constructions
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`and rely on the same evidence cited in the Reply.
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`Until Petitioner’s belated submission of the claim construction orders from
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`the WDTX and EDTX, the parties were in agreement that no claim constructions
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`were needed to determine the obviousness of the challenged claims of the ’248
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`Patent. (See Pet. at 16; POR at 7.) Notably, Petitioner’s statement that “no term
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`needs to be construed to find the asserted claims unpatentable under the Ground set
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`forth herein,” (Pet. at 16) was made without reservation to any claim construction
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`position taken by Patent Owner. As such, the claim construction orders in question
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`were not relevant to the proceeding until Petitioner introduced them, as neither side
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`believed that they were necessary to determine the issues before the Board.
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`Petitioner’s introduction of the WDTX and EDTX claim construction orders
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`was without question “new evidence or argument in reply that it could have
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`presented earlier, e.g. to make out a prima facie case of unpatentability.” TPG at 73.
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`5
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`

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`The WDTX claim construction order which issued on December 8, 2021, was
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`available to Petitioner before it filed its Reply to the POPR on December 9, 2021,
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`and the EDTX claim construction order which issued on February 8, 2022, was
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`available to Petitioner before and after the Board issued its institution decision on
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`February 9, 2022.
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`Though Petitioner attempted to characterize its arguments as a response to the
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`POR (Reply at 1), no amount of rhetorical posturing can disguise that it is Petitioner
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`that proposes constructions to the Board. Petitioner’s argument that a “software
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`scheduling agent” be limited to “a single manufacturing domain entity” (Reply at 12
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`(emphasis original)) is identical to the construction proposed by the defendants in
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`the WDTX and EDTX cases (see Ex. 1048 at 47; Ex. 1049 at 3) and seeks to narrow
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`claim language from its ordinary and customary meaning. By contrast, Patent
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`Owner’s position across both proceedings was the same as its position here: no
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`construction of this term is necessary. (See Ex. 1048 at 47; Ex. 1049 at 3.)
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`As such, each of the purportedly offending sections of Patent Owner’s Sur-
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`Reply cited in connection with the term “software scheduling agent” are within the
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`permissible scope of a sur-reply under the Board’s regulations and the TPG. Each
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`presents arguments that respond directly to Petitioner’s construction of “software
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`scheduling agent” using the same intrinsic evidence relied on by Petitioner. This
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`includes:
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`6
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`

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`• The argument at page 10, lines 1-5 of the Sur-Reply, which does
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`nothing more than note that Petitioner’s proposed construction of
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`“software scheduling agent” scheduling for “a single manufacturing
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`domain entity” (Reply at 12) fails to account for the qualifier “at least”
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`that appears in the section of the specification cited by Petitioner and
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`was included in both the EDTX and WDTX claim construction orders.
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`(Ex. 1048 at 31; Ex. 1041 at 3.)
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`• The argument at page 12, lines 4-6 of the Sur-Reply, which does
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`nothing more than point out that the portion of the file history of the
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`’248 Patent cited by Petitioner in its Reply (at 13-14) leaves open the
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`possibility that a given software scheduling agent could schedule for
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`multiple manufacturing domain entities at different times.
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`Each of these sections is narrowly responsive to arguments advanced by Petitioner
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`in support of its proposed construction of “software scheduling agent,” and each
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`relies on the same evidence and exhibits introduced by Petitioner in Petitioner’s
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`Reply Brief. That is within the permissible scope of a sur-reply. See 37 C.F.R. §
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`42.23 (“A sur-reply may only respond to arguments raised in the corresponding
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`reply.”)
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`Petitioner cannot attempt to turn the tables based on its factually incorrect
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`assertion that Patent Owner’s arguments against those belatedly-submitted claim
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`7
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`

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`constructions are themselves “new arguments.” (Mot. at 4-6.) Nor could Patent
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`Owner have “waived” (id. at 5) counter-arguments on subject matter that was not
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`included in the Petition and which Petitioner had expressly asserted were not at issue
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`in the Petition. The situation here is the exact opposite of Apple, Inc. v. Uniloc 2017
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`LLC cited by Petitioner, where waiver was based on the fact that the functions
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`identified by the Patent Owner “were not mentioned in the Reply.” IPR2019-00918,
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`Paper 21 at 18 n. 14 (P.T.A.B. Oct. 15, 2020).
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`V.
`
`PATENT OWNER’S CITATION OF THE ’248 SPECIFICATION
`WAS WITHIN THE PERMISSIBLE SCOPE OF A SUR-REPLY
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`In a further attempt to foreclose Patent Owner’s reasonable arguments in
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`response to its Reply, Petitioner has also asked the Board to strike portions of the
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`sur-reply based solely on the specification of the ’248 Patent as improper new
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`argument and/or evidence.
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`In its Reply, Petitioner argued that “[a] POSA would have found
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`implementing Gupta’s software scheduler in the semiconductor fabrication system
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`to be fairly straightforward without the need for significant redesign” (Reply at 19)
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`and that “Gupta expressly states that the six-minute time step is merely one particular
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`implementation among other possible implementations . . .” (id. at 20).
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`In response to these conclusory and non-specific arguments, Patent Owner
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`cited to portions of the specification which illustrate the complexity of the
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`scheduling required in a wafer fab and the solution proposed by the ’248 Patent, to
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`8
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`

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`emphasize the unbridgeable gaps between the limited scheduling proposed by Gupta
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`and the fab-wide system of the ’248 Patent. These citations were provided in support
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`of an argument already presented in the POR, that the six-minute scheduling of
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`Gupta is incompatible with fab-wide scheduling. (See POR at 27-28.)
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`Patent Owner is unaware of a circumstance under which citation to portions
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`of the specification already of record are considered “new evidence” or “new
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`argument” at any stage of an IPR, much less when they are provided in support of
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`arguments already presented by the same party. Moreover, Petitioner can claim no
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`prejudice with respect to citations of which it was aware, having submitted the ’248
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`Patent as Exhibit 1001 in this proceeding.
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`VI. THERE IS NO PREJUDICE TO PETITIONER
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`In keeping with the baseless assertions underlying its Motion, Petitioner’s claims
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`of prejudice based on the purportedly “new argument” in the Sur-Reply are also
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`without substance. The only prejudice identified by Petitioner for any of the
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`sections it requests that the Board strike is that Patent Owner “prevented Applied
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`from addressing this argument in its reply,” (Mot. at 9, regarding the section on the
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`prosecution history), and “Petitioner was unable to address this argument in its
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`reply” (id. at 10, regarding the six-minute time step in Gupta). As all of the
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`arguments made by Patent Owner are responses to arguments made by Petitioner
`
`in its Reply, and do not substantially differ from arguments already made by Patent
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`9
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`

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`Owner in the POR, there is no foundation to Petitioner’s claims of prejudice. See
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`Idemitsu Kosan Co. v. SFC Co., 870 F.3d 1376, 1381 (Fed. Cir. 2017) (“This back-
`
`and-forth shows that what Idemitsu characterizes as an argument raised ‘too late’ is
`
`simply the by-product of one party necessarily getting the last word.”)
`
`To the extent that the Board determines that any of the arguments made by
`
`Patent Owner are in fact new argument outside the scope of a sur-reply, basic
`
`principles of fairness and equity still preclude granting Petitioner’s Motion, in light
`
`of Petitioner’s own inclusion of new argument and evidence in its Reply. See 37
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`C.F.R. § 42.1(b) (“This part shall be construed to secure the just, speedy, and
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`inexpensive resolution of every proceeding.”) Both parties will have the
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`opportunity to address the Board on all issues at Oral Argument.
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`VII. CONCLUSION
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`In an undeserved attempt to have the last word on the issues in this
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`proceeding, Petitioner seeks to strike multiple portions of Patent Owner’s Sur-
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`Reply that are responsive to arguments and evidence presented by Petitioner in its
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`Reply. The facts surrounding Petitioner’s Motion, as well as principles of
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`procedural fairness and the Board’s rules, indicate that Petitioner’s Motion should
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`be denied as to every cited portion of the Sur-Reply.
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`10
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`

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`Dated: October 14, 2022
`
`
`
`DEVLIN LAW FIRM LLC
`
`/ Timothy Devlin /
`Timothy Devlin
`Registration No. 41,706
`TD-PTAB@devlinlawfirm.com
`Alex Chan
`Registration No. 52,713
`achan@devlinlawfirm.com
`1526 Gilpin Ave.
`Wilmington, DE 19806
`(302) 449-9010
`
`Attorneys for Patent Owner
`
`
`
`
`
`11
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`

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`CERTIFICATE OF SERVICE
`
`The undersigned certifies that the foregoing document was served
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`electronically via electronic mail on October 14, 2022, on the following counsel of
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`record for Petitioners:
`
`COUNSEL FOR APPLIED MATERIALS, INC.
`LEAD COUNSEL
`BACKUP COUNSEL
`
`
`Pan C. Lee (admitted pro hac vice)
`Eric A. Krause (Reg. No. 62,329)
`Jeannine Yoo Sano (admitted pro hac vice)
`ekrause@axinn.com
`Don Zhe Nan Wang (admitted pro hac vice)
`
`Axinn Veltrop & Harkrider LLP
`plee@axinn.com
`560 Mission Street
`jsano@axinn.com
`San Francisco, California 94105
`dwang@axinn.com
`Telephone: (415) 490-1491
`
`Facsimile: (415) 490-2001
`Axinn, Veltrop & Harkrider LLP
`
`560 Mission Street
`San Francisco, CA 94105
`Phone: (415) 490-1488
`
`Additional email for service: applied-ocean@axinn.com
`
`/s/ Timothy Devlin
` Timothy Devlin
`
`
`
`
`12
`
`