Case 6:20-cv-01215-ADA Document 28 Filed 06/04/21 Page 1 of 13
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`UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`NO. 6:20-cv-01215-ADA
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`OCEAN SEMICONDUCTOR LLC,
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`Plaintiff,
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`vs.
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`STMICROELECTRONICS, INC.,
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`Defendant.
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`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
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`STMICROELECTRONICS, INC.’S OPPOSITION TO OCEAN SEMICONDUCTOR’S
`MOTION FOR PRE-TRIAL CONSOLIDATION
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`
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`IPR2021-01342
`Ocean Semiconductor Exhibit 2032
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`

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`Case 6:20-cv-01215-ADA Document 28 Filed 06/04/21 Page 2 of 13
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`INTRODUCTION ............................................................................................................. 1
`LEGAL STANDARD ........................................................................................................ 2
`ARGUMENT ..................................................................................................................... 2
`A.
`Ocean Fails to Show “Common Question[s] of Fact and Law” ............................ 3
`B.
`Consolidation Would Lead to Confusion and Prejudice Defendants .................... 6
`C.
`Consolidation Would Not Significantly Reduce the Time or Cost of
`Litigation ................................................................................................................ 9
`CONCLUSION ................................................................................................................ 10
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`I.
`II.
`III.
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`IV.
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`IPR2021-01342
`Ocean Semiconductor Exhibit 2032
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`

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`Case 6:20-cv-01215-ADA Document 28 Filed 06/04/21 Page 3 of 13
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`CASES
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`Aerotel Ltd. v. Verizon Comms. Inc.,
`234 F.R.D. 64 (S.D.N.Y. 2005) .................................................................................................7
`
`Certified/LVI Envtl. Servs., Inc. v. PI Constr. Corp.,
`No. SA-01-CA-1036, 2003 WL 1798542 (W.D. Tex. Mar. 3, 2003)........................................2
`
`Cont’l Bank & Trust Co. v. Platzer,
`304 F. Supp. 228 (S.D. Tex. 1969) ............................................................................................2
`
`Dupont v. S. Pac. Co.,
`366 F.2d 193 (5th Cir. 1966) .....................................................................................................7
`
`Fenner Invs., Ltd. v. 3Com Corp.,
`No. CIV.A.6:08-CV-61, 2008 WL 4876816 (E.D. Tex. Nov. 12, 2008) ..................................4
`
`Lay v. Spectrum Clubs, Inc.,
`No. 5:12-cv-00754, 2013 WL 788080 (W.D. Tex. Mar. 1, 2013) .............................................6
`
`Ocean Semiconductor LLC v. MediaTek Inc.,
`No. 6:20-1210 (W.D. Tex. 2020) ...............................................................................................3
`
`St. Bernard Gen. Hosp., Inc. v. Hosp. Serv. Ass’n of New Orleans, Inc.,
`712 F.2d 978 (5th Cir. 1983) .....................................................................................................8
`
`Talon Research, LLC v. Toshiba Am. Elec. Components, Inc.,
`Case No. 4:11-cv-4819-CW (N.D. Cal. Mar. 5, 2012) ..............................................................4
`
`YETI Coolers, LLC v. RTIC Coolers, LLC,
`No. 1:16-CV-909-RP, 2017 WL 5505325 (W.D. Tex. Jan. 18, 2017) ..........................2, 3, 5, 7
`
`RULES
`
`FED. R. CIV. P. 42(a) ........................................................................................................................2
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`
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`IPR2021-01342
`Ocean Semiconductor Exhibit 2032
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`

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`Case 6:20-cv-01215-ADA Document 28 Filed 06/04/21 Page 4 of 13
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`I.
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`INTRODUCTION
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`STMicroelectronics, Inc. (“ST Inc.”) opposes Ocean Semiconductor LLC’s (“Ocean”)
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`Motion for Pre-Trial Consolidation (Dkt. 26) (“Motion”) of seven cases against disparate
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`defendants (“Defendants”). The Motion is premised on Ocean’s assertion that there are common
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`questions of fact and law because the seven cases against Defendants allegedly implicate
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`overlapping patents, foundry partners, manufacturing tools, and tool suppliers. But that premise
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`is faulty. Ocean’s allegations are directed to seven distinctly-situated defendants, some of whom
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`fabricate their own semiconductor products and some of whom are “fabless” and use contract
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`manufacturers to make their products. Ocean’s allegations also involve distinct accused products;
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`distinct and non-overlapping relationships between each Defendant, the various foundries, and tool
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`or software suppliers; and distinct facts with regard to direct infringement, indirect infringement,
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`damages, and willful infringement. In short, the various cases involve very different questions of
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`fact and law for each of the seven Defendants. Moreover, discovery is likely to yield even more
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`divergence among the cases, as Ocean has yet to serve its infringement contentions and admits that
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`its current list of foundries and tool or software suppliers may be incomplete. Ocean’s Motion is
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`thus premature.
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`But even based on the current record, no efficiencies would be gained from consolidation.
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`The Court routinely coordinates schedules and Markman hearings and streamlines discovery
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`where plaintiffs have asserted the same patents, without the need for formal consolidation. The
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`primary efficiency sought by Ocean—an extraordinary request for “consolidated briefing,”
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`including consolidated summary judgment briefing—is inconsistent with the Court’s procedures.
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`Indeed, Ocean can point to no other case where the Court has ever implemented that requested
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`approach in other consolidated matters. Granting Ocean’s request would significantly prejudice
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`Defendants and hamper ST Inc.’s ability to defend itself among six other Defendants who
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`IPR2021-01342
`Ocean Semiconductor Exhibit 2032
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`Case 6:20-cv-01215-ADA Document 28 Filed 06/04/21 Page 5 of 13
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`manufacture different products in different ways with different tools and software to make
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`different accused products. On the other hand, denying consolidation would not prejudice Ocean.
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`Ocean cannot reasonably complain about the work required to prosecute these matters when any
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`alleged “harm” results entirely from its tactical decision to sue seven Defendants in this Court at
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`the same time. There is no need for formal consolidation, and Ocean’s request should be denied.
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`II.
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`LEGAL STANDARD
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`In weighing whether to consolidate actions under Federal Rule of Civil Procedure 42(a),
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`courts consider factors such as whether the actions are pending before the same court; whether the
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`actions involve a common party; whether there is any risk of prejudice or confusion; whether there
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`might be inconsistent adjudications of common factual or legal questions if the matters are tried
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`separately; whether there is risk of cost or delay in trying the cases separately; and whether the
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`cases are at the same stage of preparation for trial. YETI Coolers, LLC v. RTIC Coolers, LLC, No.
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`1:16-CV-909-RP, 2017 WL 5505325, at *2 (W.D. Tex. Jan. 18, 2017) (citations omitted).
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`However, “the mere presence of a common question of law or fact does not require consolidation”
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`but must be balanced against “inconvenience, delay and confusion that might result.” Cont’l Bank
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`& Trust Co. v. Platzer, 304 F. Supp. 228, 229 (S.D. Tex. 1969). Ocean bears the burden to show
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`that consolidation is warranted. See Certified/LVI Envtl. Servs., Inc. v. PI Constr. Corp., No. SA-
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`01-CA-1036, 2003 WL 1798542, *2 (W.D. Tex. Mar. 3, 2003).
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`III. ARGUMENT
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`The Court should deny Ocean’s request for consolidation because (1) Ocean cannot meet
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`the threshold requirement to show common questions of law and fact; (2) pre-trial consolidation
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`would lead to confusion and prejudice Defendants; and (3) consolidation would not significantly
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`reduce the time or cost of litigating the cases.
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`IPR2021-01342
`Ocean Semiconductor Exhibit 2032
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`

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`Case 6:20-cv-01215-ADA Document 28 Filed 06/04/21 Page 6 of 13
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`A.
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`Ocean Fails to Show “Common Question[s] of Fact and Law”
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`As an initial matter, the Motion should be denied because Ocean cannot meet the
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`“threshold” showing that the seven cases share “common question[s] of law or fact” to warrant
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`consolidation. YETI, 2017 WL 5505325, at *2. While Ocean has accused each Defendant of
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`infringing 7–9 patents, the accused products for each Defendant are different. Ocean’s Complaint
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`broadly identifies ST Inc.’s “semiconductor products in the communications, internet of things,
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`automotive, computer, and consumer electronics industry (‘Accused Products’)”—categories that
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`potentially encompass hundreds of different products. Dkt. 1 at ¶ 7. For the ’305 Patent alone,
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`Ocean purports to accuse hundreds of disparate ST Inc. products:
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`advanced driver assistance systems, . . . MEMs and sensor products, . . .
`microprocessors, . . . amplifiers, diodes, rectifiers, comparators, automotive
`devices, clocks and timers, converters, set-top boxes ICs, logic ICs, transceivers,
`memories, drivers, transistors, switches, voltage regulators, systems-on-chip (SoC),
`or similar products for mobile devices, wearables, banking, identification,
`industrial, communications, energy, automotive, personal electronics, sensing,
`cloud, and Internet of Things applications, and similar systems, products, devices,
`and integrated circuits.
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`Dkt. 1, Ex. N at 1. None of these products overlaps with the hundreds of other purported accused
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`products relating to the other Defendants. Cf., e.g., Ocean Semiconductor LLC v. MediaTek Inc.,
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`No. 6:20-1210 (W.D. Tex. 2020), Dkt. 1 at ¶¶ 7, 15 (accusing over 100 other semiconductor
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`products used in phones, tablets, and networking devices). Ocean also alleges that ST Inc. itself
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`allegedly designs, develops, sells, offers to sell, and imports products alleged to infringe, while
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`using foundries such as Taiwan Semiconductor Manufacturing Company (“TSMC”)1 and United
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`Microelectronics Corporation (“UMC”) to allegedly perform the patented methods during
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`1 Even with respect to TSMC, it is highly unlikely that the factual inquiry will be the same for each Defendant. TSMC
`has facilities across the world, with differing processing capabilities, different tools and methods, and different
`products that are fabricated. Thus, the factual inquiry to establish non-infringement for one Defendant may have no
`bearing on whether another Defendant’s accused products are manufactured using the same method.
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`IPR2021-01342
`Ocean Semiconductor Exhibit 2032
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`

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`Case 6:20-cv-01215-ADA Document 28 Filed 06/04/21 Page 7 of 13
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`manufacturing of some products. Dkt. 1 at ¶¶ 8, 9. Ocean further alleges that ST Inc. and the
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`foundries use allegedly infringing semiconductor-manufacturing tools and software, including
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`ASML’s Twinscan and Yieldstar tools, Applied Materials’ E3 system, PDF Solutions’ Exensio
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`system, camLine’s LineWorks system, and/or other unnamed “in-house or third-party
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`advanced/automation process control system and platform hardware and/or software.” See, e.g.,
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`Dkt. 1 at ¶¶ 10–26.
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`At a high level, Ocean assumes that common questions of fact and law exist because there
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`are overlapping patents and all seven Defendants are accused of manufacturing devices through
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`foundries using allegedly infringing tools or software. However, the fact that validity and
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`infringement of overlapping patents is at issue in separate actions does not justify consolidation
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`because Ocean’s infringement contentions remain unique to each Defendant and their individual
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`circumstances. See, e.g., Fenner Invs., Ltd. v. 3Com Corp., No. CIV.A.6:08-CV-61, 2008 WL
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`4876816, at *1 (E.D. Tex. Nov. 12, 2008) (denying consolidation where validity and infringement
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`of same patents were at issue in separate cases); Talon Research, LLC v. Toshiba Am. Elec.
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`Components, Inc., Case No. 4:11-cv-4819-CW, Dkt No. 70 (N.D. Cal. Mar. 5, 2012) (denying
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`motion to relate cases involving a single patent because Section 299 of the America Inventions
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`Act evinces Congress’s intent to not group multiple, unrelated defendants together simply because
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`they allegedly infringe the same patent). Tellingly, Ocean has made no showing that the various
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`noninfringement defenses and noninfringement facts that each Defendant will raise will be the
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`same. For example, Ocean provides nothing to support that the Defendants or their foundries use
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`the identified tools and software in the same way to make the purportedly accused products.
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`In YETI, this Court denied a motion to consolidate a set of cases involving drinkware
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`products with separate cases involving soft-sided coolers even though the plaintiff, RTIC, accused
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`IPR2021-01342
`Ocean Semiconductor Exhibit 2032
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`

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`Case 6:20-cv-01215-ADA Document 28 Filed 06/04/21 Page 8 of 13
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`the same defendant, YETI, using mirror-image legal claims of patent and trade dress infringement.
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`2017 WL 5505325, at *1. The Court was not persuaded that there were “common question[s] of
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`fact and law” “simply because [the cases] involve the same types of claims and the products at
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`issue happen to be manufactured by the same companies.” Id. at *2. Rather, “the factual inquiries
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`RTIC believe are common to these cases are actually different inquiries relating to different
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`products, with different appearances and different designs.” Id.
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`The holding in YETI applies here, and with greater force given that the parties also differ
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`across the cases. Some Defendants, such as MediaTek are “fabless” and rely entirely on contract
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`manufacturers to fabricate their products, while other Defendants, such as ST Inc., sell products
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`fabricated by other manufacturers as well as affiliated entities. No two cases are alike. For
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`example, as shown in the table below, each Defendant is uniquely situated as to Ocean’s
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`combination of infringement allegations relating to fabrication by each Defendant and/or by
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`foundries (e.g., TSMC, UMC) and use of Applied Material’s SmartFactory and/or camLine’s
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`LineWorks software. And the table provides just a snapshot of the differences relating to a subset
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`of Ocean’s infringement allegations across the Defendants.
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`TSMC
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`Manufacturing entities
`TSMC,
`TSMC,
`Own Fab
`UMC
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`
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`TSMC, UMC,
`Own Fab
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`ST Inc.*
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`TSMC,
`Kioxa, Own
`Fab
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`
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`MediaTek
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`NXP*
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`NVIDIA**
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`
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`Western
`Digital
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`camLine’s
`LineWorks
`Applied
`Materials’
`SmartFactory
`Both
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`Silicon
`Labs
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`Renesas
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`
`
`
`
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`Software
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` *
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`**
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`Ocean also asserts the ’097 Patent.
`Ocean also asserts the ’170 and ’383 Patents.
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`IPR2021-01342
`Ocean Semiconductor Exhibit 2032
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`

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`Case 6:20-cv-01215-ADA Document 28 Filed 06/04/21 Page 9 of 13
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`Moreover, Ocean reserves the right to add infringement theories based on additional
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`foundries, importers, and tools, suggesting that its Motion is premature and leaving open the
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`possibility that the cases will diverge even more once Ocean serves its infringement contentions
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`and discovery progresses. Dkt. 26 at nn. 1, 2. Indeed, Ocean’s Complaint merely alleges that “at
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`least one claim” of any given patent has been infringed by each Defendant, so it is not at all clear
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`that the Defendants will be accused of infringing the same claims. See, e.g., Dkt. 1 at ¶¶ 94, 134.
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`Further, to the extent Ocean is attempting to limit the number of prior art references the Defendants
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`can rely on, its request is premature because the Court specifies that such narrowing takes place
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`months after the Markman hearing, not through pre-Markman consolidation. Order Governing
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`Proceedings – Patent Case Version 3.3 (“OGP”), at p. 9.
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`Ocean cannot meet its burden to show common questions of fact and law sufficient to
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`warrant consolidation of the seven cases.
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`B.
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`Consolidation Would Lead to Confusion and Prejudice Defendants
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`Contrary to Ocean’s conclusory statement that there would be “no risk of prejudice or
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`confusion if the actions are consolidated,” Dkt. 26 at 1, consolidation would prejudice the
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`Defendants in significant ways. First, Ocean’s request for “consolidated briefing” is inherently
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`prejudicial because it seeks to impose briefing limits more stringent than what this Court currently
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`requires. Id. at 6–7. During the parties’ meet and confer, Ocean suggested that its Motion
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`contemplates summary judgment briefing that would require all seven Defendants to submit a
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`single summary judgment brief, with a page limit per Defendant that is far less than the Court’s
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`rules provide for each Defendant in an individual case.2 This request contradicts the Court’s
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`2 Notably, Ocean provides no authority to support its request that, if consolidated, Defendants should have to file joint
`briefs even for dispositive motions. Cf. Lay v. Spectrum Clubs, Inc., No. 5:12-cv-00754, 2013 WL 788080, at *2
`(W.D. Tex. Mar. 1, 2013) (consolidation “does not merge the suits into a single action or change the rights of the
`parties”).
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`IPR2021-01342
`Ocean Semiconductor Exhibit 2032
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`

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`Case 6:20-cv-01215-ADA Document 28 Filed 06/04/21 Page 10 of 13
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`explicit procedures, which impose no limit on the number of motions for summary judgment, but
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`specify a cumulative page limit of 40 pages “per side” for summary judgment briefing. OGP, at
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`p. 6. The Court notes that if it “consolidates related cases for pretrial purposes, with regard to
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`calculating limits . . ., a ‘side’ shall be interpreted as if the cases were proceeding individually.”
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`Under that approach, each Defendant would receive 40 pages of summary judgment briefing. Id.
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`Ocean’s request for “consolidated briefing” would thus provide ST Inc. and each of the other
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`Defendants with fewer rights than what a typical defendant in this Court would enjoy. See Dupont
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`v. S. Pac. Co., 366 F.2d 193, 196 (5th Cir. 1966) (“Where prejudice to rights of the parties
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`obviously results from the order of consolidation, the action of the trial judge has been held
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`reversible error.”). The potential prejudice from Ocean’s proposed joint briefing for all Defendants
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`is particularly acute for ST Inc. As shown in the chart above, Ocean asserts the ’097 Patent against
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`just two Defendants: ST Inc. and NXP. Defending against Ocean’s allegations will require unique
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`invalidity, noninfringement, and claim construction arguments specific to the ’097 Patent—issues
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`that the other Defendants have no incentive to address in any consolidated briefing. Those
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`circumstances would make it more difficult for ST Inc. to have its arguments heard by the Court
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`and result in prejudice.
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`Second, consolidation would complicate discovery and lead to confusion regarding the
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`disparate positions of the various parties. As the Court found in YETI, consolidation “would lead
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`to one significantly more complex case, rather than three relatively simple ones.” 2017 WL
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`5505325, at *3. Here, Ocean has accused hundreds of individual products made by the seven
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`Defendants. The different combinations of parties, products, foundries, manufacturing
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`approaches, software, tools, and suppliers in each case mean that different and non-overlapping
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`facts, evidence, claim constructions, and defenses will develop. Consolidation would also
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`IPR2021-01342
`Ocean Semiconductor Exhibit 2032
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`Case 6:20-cv-01215-ADA Document 28 Filed 06/04/21 Page 11 of 13
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`complicate fact and expert witness depositions and could lead to testimony about various parties
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`and issues that would confuse a jury. Consolidation would also require the different Defendants
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`to participate in discovery—and incur additional and unnecessary discovery costs—for evidence
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`that may not be relevant to their own products and defenses. See, e.g., Aerotel Ltd. v. Verizon
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`Comms. Inc., 234 F.R.D. 64, 66 (S.D.N.Y. 2005) (substantial non-overlap of issues would lead to
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`increased discovery costs). In addition, Western Digital’s two pending IPRs could create
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`significant confusion in a potential consolidated case. In both IPRs, Western Digital stipulated
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`that it will not “pursue invalidity on the same grounds in district court” if the PTAB institutes the
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`IPRs. See IPR No. 2021-00864, Paper 1 at 6; IPR No. IPR2021-00929, Paper 1 at 7. That
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`limitation does not apply to any other Defendant.
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`Denying the request for consolidation would not create any prejudice to Ocean. Although
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`Ocean argues it would be prejudiced because it has already responded to seven different motions
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`to dismiss pending before this Court, Dkt. 26 at 7, it ignores its own choice to file seven different
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`complaints against seven different entities.3 Each Defendant is entitled to pursue its own
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`independent defense and briefing, especially for the fact-specific briefing required when
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`responding to a motion to dismiss.
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`Because the risk of prejudice to Defendants is high, but the risk of prejudice to Ocean is
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`low, consolidation would be improper. See St. Bernard Gen. Hosp., Inc. v. Hosp. Serv. Ass’n of
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`New Orleans, Inc., 712 F.2d 978, 989 (5th Cir. 1983).
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`3 Ocean’s argument also ignores its choice to not sue the suppliers, whose tools and modules are the actual targets of
`these allegations, but rather pursue seven different customers in this Court. This tactical decision undermines Ocean’s
`claims of judicial economy.
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`IPR2021-01342
`Ocean Semiconductor Exhibit 2032
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`

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`Case 6:20-cv-01215-ADA Document 28 Filed 06/04/21 Page 12 of 13
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`C.
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`Consolidation Would Not Significantly Reduce the Time or Cost of Litigation
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`Ocean contends that consolidation will promote judicial efficiency through consolidated
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`discovery but does not identify any particular procedures beyond “consolidated briefing” that
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`would help attain that goal. Mot. at 6–7. In fact, this Court already has procedures in place for
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`scheduling, discovery, claim construction, and briefing to streamline the disposition of related
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`cases, and consolidation would not yield any additional efficiencies that would significantly reduce
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`the time or cost of litigation. For example, the Court may enter a coordinated schedule and hold a
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`joint Markman hearing, and as discussed above, the Court already imposes consistent limits “per
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`side” whether or not cases are consolidated. See OGP at p. 2 n.2 (“In the event that the Court
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`consolidates related cases for pretrial purposes, with regard to calculating limits imposed by this
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`Order, a “side” shall be interpreted as if the cases were proceeding individually.”). Ocean also
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`ignores that any efficiency gains would be outweighed by the significant prejudice to Defendants
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`described above.
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`Ocean further argues that, without consolidation, “[t]he defendants [] would be able each
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`to allege a different set of alleged prior art—such that the collective asserted art far exceeds this
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`Court’s normal per-action limits.” Dkt. 26 at 4. That is simply incorrect. The Court does not
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`impose any “per-action limits” for Defendants’ initial invalidity contentions. OGP, at ¶ 6. And
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`the Court already requires parties to meet and confer post-Markman to discuss limiting the number
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`of prior art references raised at trial. Id. at p. 7.
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`At bottom, Ocean seeks not judicial economy, but an advantage in litigation by reducing
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`Defendants’ briefing throughout the litigation, as well as its own workload in pursuing seven
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`different cases simultaneously. Consolidation would yield no particular efficiencies, but it would
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`create one massively complex seven-defendant case implicating different parties, products, and
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`IPR2021-01342
`Ocean Semiconductor Exhibit 2032
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`

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`Case 6:20-cv-01215-ADA Document 28 Filed 06/04/21 Page 13 of 13
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`issues. Under the circumstances, each case should proceed individually under the Court’s current
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`procedures.
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`IV. CONCLUSION
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`For the foregoing reasons, the Court should deny Ocean’s request to consolidate.
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`
`Dated: June 4, 2021
`
`
`Respectfully submitted,
`
`/s/ Tyler R. Bowen
`Janice L. Ta, Texas 24075138
`JTa@perkinscoie.com
`Perkins Coie LLP
`500 West Second St., Suite 1900
`Austin, TX 78701
`
`Chad S. Campbell (admitted pro hac vice)
`CSCampbell@perkinscoie.com
`Tyler R. Bowen (admitted pro hac vice)
`TBowen@perkinscoie.com
`Perkins Coie LLP
`2901 North Central Avenue, Suite 2000
`Phoenix, AZ 85012
`
`Philip A. Morin (admitted pro hac vice)
`PMorin@perkinscoie.com
`Yudong Kim (admitted pro hac vice)
`YKim@perkinscoie.com
`Perkins Coie LLP
`11452 El Camino Real, Suite 300
`San Diego, CA 92130-2020
`
`ATTORNEYS FOR DEFENDANT
`STMICROELECTRONICS, INC.
`
`
`
`CERTIFICATE OF SERVICE
`I hereby certify that on June 4, 2021, a true and correct copy of the above and foregoing
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`document has been served on all counsel of record via the Court’s CM/ECF system.
`
`
`
`
`/s/ Tyler R. Bowen
`Tyler R. Bowen
`
`
`
`IPR2021-01342
`Ocean Semiconductor Exhibit 2032
`
`