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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`____________
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`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________
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`APPLE INC.,
`Petitioner
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`v.
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`SCRAMOGE TECHNOLOGY LTD.,
`Patent Owner
`____________
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`IPR2022-00351
`Patent 10,622,842
`____________
`
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`PATENT OWNER’S PRELIMINARY RESPONSE
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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
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`
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`Table of Contents
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`B.
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`C.
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`INTRODUCTION ............................................................................................. 1
`I.
`II. ALL FINTIV FACTORS WEIGH AGAINST INSTITUTION ........................ 1
`Factor 1: The district court has not granted a stay, nor is there any
`A.
`evidence that a stay will be granted. .................................................... 3
`Factor 2: The district court trial will occur before the deadline for a
`final decision in this proceeding. ......................................................... 5
`Factor 3: By the time an institution decision is reached, the parties and
`the court will have completed claim construction and discovery will
`be nearly closed. ................................................................................... 7
`Factor 4: There is complete overlap between this IPR and the district
`court proceedings. ................................................................................ 9
`Factor 5: Petitioner is a defendant in the district court litigation. ...... 11
`E.
`Factor 6: The petition is without merit and unlikely to succeed. ....... 11
`F.
`III. CONCLUSION ................................................................................................ 12
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`D.
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`i
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`PATENT OWNER’S EXHIBIT LIST
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`Exhibit No. Description
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`2001
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`2002
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`2003
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`2004
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`2005
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`2006
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`2007
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`2008
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`2009
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`2010
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`Notice of IPR Petitions, Scramoge Technology Ltd. v. Apple Inc.,
`Case No. 6:21-cv-00579-ADA, Dkt. No. 42 (W.D. Tex. Jan. 7,
`2022)
`
`Scheduling Order, Scramoge Technology Ltd. v. Apple Inc., Case
`No. 6:21-cv-00579-ADA, Dkt. No. 33 (W.D. Tex. Sept. 28, 2021)
`
`Law360 Article: West Texas Judge Says He Can Move Faster
`Than PTAB
`
`Text Order Denying Motion to Stay Pending IPR, Solas OLED
`Ltd. v. Google, Inc., Case No. 6:19-cv-00515-ADA (W.D. Tex.
`June 23, 2020)
`
`Order Denying Motion to Stay Pending IPR, Multimedia Content
`Management LLC v. DISH Network L.L.C., Case No. 6:18-cv-
`00207-ADA, Dkt. No. 73 (W.D. Tex. May 30, 2019)
`
`Scheduling Order, Correct Transmission LLC v. Adtran, Inc.,
`Case No. 6:20-cv-00669-ADA, Dkt. No. 34 (W.D. Tex. Dec. 10,
`2020)
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`Scheduling Order, Maxell Ltd. v. Amperex Technology Ltd., Case
`No. 6:21-cv-00347-ADA, Dkt. No. 37 (W.D. Tex. Nov. 8, 2021)
`
`Standing Order Governing Proceedings in Patent Cases (OGP)
`4.1, Judge Alan D. Albright (April 14, 2022)
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`Claim Construction Order, Solas OLED Ltd. v. Apple Inc., Case
`No. 6:19-cv-00537-ADA, Dkt. No. 61 (W.D. Tex. Aug. 30, 2020)
`
`Plaintiff Scramoge Technology Ltd.’s Amended Preliminary
`Disclosure of Asserted Claims and Infringement Contentions to
`Apple Inc. in Scramoge Technology Ltd. v. Apple Inc., Case No.
`6:21-cv-00579-ADA (W.D. Tex.)
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`
`
`ii
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`
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`2011
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`2012
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`2013
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`2014
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`2015
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`Defendant Apple Inc.’s First Amended Preliminary Invalidity
`Contentions in Scramoge Technology Ltd. v. Apple Inc., Case No.
`6:21-cv-00579-ADA (W.D. Tex.)
`
`Android Authority article: LG Innotek’s Latest wireless charger is
`Three times faster
`
`Scheduling Order, Scramoge Technology Ltd. v. Google LLC,
`Case No. 6:21-cv-00616-ADA, Dkt. No. 28 (W.D. Tex. Nov. 15,
`2021)
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`Defendants’ Joint Reply Claim Construction Brief in Scramoge
`Technology Ltd. v. Apple Inc., Case No. 6:21-cv-00579-ADA
`(W.D. Tex.)
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`Scheduling Order, Scramoge Technology Ltd. v. Apple Inc., Case
`No. 6:21-cv-00579-ADA, Dkt. No. 56 (W.D. Tex. Feb. 11, 2022)
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`iii
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`IPR2022-00351 (’842 Patent)
`Patent Owner Preliminary Response
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`I.
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`INTRODUCTION
`Patent Owner Scramoge Technology Ltd. (“Patent Owner”) submits this
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`preliminary response to Petitioner Apple Inc.’s (“Petitioner”) petition for inter
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`partes review of U.S. Patent No. 10,622,842 (“’842 patent”).
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`The Board should exercise its discretion to deny the petition in light of a
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`parallel district court case involving the same patent, the same claims, the same prior
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`art, and the same parties. By the time the Board reaches an institution decision in
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`this proceeding, the parties and the district court will have already invested
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`significant time and resources in the case—the parties will have already exchanged
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`final infringement and invalidity contentions, claim construction will be completed
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`and discovery will nearly be closed. The district court trial is also on track to take
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`place five months before the deadline for a final written decision. Moreover, because
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`the Fintiv factors so strongly favor a discretionary denial, the Board need not
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`consider the merits. Thus, all six Fintiv factors strongly favor a discretionary denial.
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`Accordingly, the Board should deny institution.
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`II. ALL FINTIV FACTORS WEIGH AGAINST INSTITUTION
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`35 U.S.C. § 314(a) gives the Board discretion to deny institution of the
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`requested inter partes review due to the advanced state of parallel district court
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`litigation regarding the same issues. See NHK Spring Co. v. Intri-Plex Techs., Inc.,
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`IPR2018-00752, Paper 8 (PTAB Sept. 12, 2018) (precedential, designated May 7,
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`1
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`IPR2022-00351 (’842 Patent)
`Patent Owner Preliminary Response
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`2019) (“NHK Spring”). The Board has set forth six factors for determining whether
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`discretionary denial due to such parallel litigation is appropriate (the “Fintiv
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`factors”):
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`1.
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`2.
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`3.
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`4.
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`5.
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`6.
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`whether the court granted a stay or evidence exists that one may be
`granted if a proceeding is instituted;
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`proximity of the court’s trial date to the Board’s projected statutory
`deadline for a final written decision;
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`investment in the parallel proceeding by the court and the parties;
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`overlap between issues raised in the petition and in the parallel
`proceeding;
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`whether the petitioner and the defendant in the parallel proceeding are
`the same party; and
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`other circumstances that impact the Board’s exercise of discretion,
`including the merits.
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`Apple Inc. v. Fintiv, Inc., IPR2020-00019, Paper 11 at 5–6 (PTAB Mar. 20, 2020)
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`(precedential, designated May 5, 2020) (“Fintiv I”); Apple Inc. v. Fintiv, Inc.,
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`IPR2020-00019, Paper 15 at 7–8 (PTAB May 13, 2020) (decision denying
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`institution of inter partes review) (“Fintiv II”). “These factors relate to whether
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`efficiency, fairness, and the merits support the exercise of authority to deny
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`institution in view of an earlier trial date in the parallel proceeding.” Fintiv I at 6. In
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`evaluating the factors, “the Board takes a holistic view of whether efficiency and
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`integrity of the system are best served by denying or instituting review.” Id.
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`2
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`IPR2022-00351 (’842 Patent)
`Patent Owner Preliminary Response
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`As set forth below, all six Fintiv factors weigh against institution. The district
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`court trial will precede any final written decision from the Board. To avoid
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`duplication of efforts, wasting resources, and potentially inconsistent decisions, the
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`Board should deny institution.
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`A.
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`Factor 1: The district court has not granted a stay, nor is there any
`evidence that a stay will be granted.
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`The ’842 patent is asserted in the Western District of Texas before Judge
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`Albright in Scramoge Technology Ltd. v. Apple Inc., No. 6-21-cv-00579 (“Apple
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`case”). As discussed further below, the Apple case involves the same parties and
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`issues as the requested IPR. The district court is aware of Petitioner’s pending IPR
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`petition,1 but has not stayed the case. Nor is there any evidence that the case will be
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`stayed.
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`To the contrary, the district court has entered scheduling orders, and the Apple
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`case is on track for trial in early 2023. See Ex. 2002 (Scheduling Order); Ex. 2013
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`(Scheduling Order in Scramoge Technology Ltd. v. Google, LLC, No. 6-21-cv-
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`00616-ADA (“Google case”) setting trial for Feb. 27, 2023). And none of the
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`1 Patent Owner filed a Notice of IPR Petition in the district court, which states that
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`defendant/Petitioner filed an IPR petition regarding claims of the ’842 patent. Ex.
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`2001 at 1.
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`3
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`IPR2022-00351 (’842 Patent)
`Patent Owner Preliminary Response
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`defendants, including Petitioner, have even filed motions to stay—likely because
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`Judge Albright does not favor stays pending IPR proceedings. See Ex. 2003 (Law360
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`Article: West Texas Judge Says He Can Move Faster Than PTAB) (Judge Albright:
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`“It’s my job to give people the opportunity to have their cases tried in a federal court
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`. . . and I probably can get a patent trial resolved more quickly than the PTAB can.”).
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`Indeed, Petitioner does not indicate in its Petition that it intends to seek a stay, and
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`only admits that “[n]o motion to stay has been filed.” Petition at 11. See Samsung
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`Elecs. Co. Ltd. v. Evolved Wireless LLC, IPR2021-00950, Paper 10 at 10–11 (PTAB
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`Nov. 29, 2021) (“Evolved”) (finding this factor weighed in favor of denial and
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`denying institution where patent owner showed a stay was unlikely based on the
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`advanced stage of the case and the court’s past decisions denying stays).
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`Regardless, by the deadline for an institution decision (August 9, 2022), the
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`parties will have already exchanged final infringement and invalidity contentions,
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`discovery will nearly be closed (close of fact discovery is September 13, 2022), and
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`claim construction will be completed (the Markman hearing is scheduled for May
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`23, 2022). See Ex. 2015. Thus, even if Petitioner ultimately files a motion to stay, it
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`is highly unlikely that Judge Albright would grant a stay at that late juncture in the
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`case. See, e.g., Ex. 2004 (Order denying motion to stay pending IPR where plaintiff
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`had served its preliminary infringement contentions and where claim construction
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`was scheduled to begin before the IPR institution deadline); Ex. 2005 at 5 (Order
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`4
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`IPR2022-00351 (’842 Patent)
`Patent Owner Preliminary Response
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`denying stay pending IPR even though discovery had not yet begun, as the district
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`court had already “invested significant resources and time in construing all the
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`contested claim terms”).
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`As explained by the Board, a stay of the district court litigation pending
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`resolution of the PTAB proceedings “allays concerns about inefficiency and
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`duplication of efforts.” Fintiv I at 6; Fintiv II at 12. But here, the district court has
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`not stayed the pending litigation, nor is there any evidence that a stay will be granted.
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`Allowing this IPR to proceed simultaneously with the district court litigation would
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`be wasteful and inefficient. This factor weighs against institution.
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`B.
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`Factor 2: The district court trial will occur before the deadline for
`a final decision in this proceeding.
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`The statutory deadline for a final written decision in this proceeding is August
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`9, 2023, which can be extended to February 9, 2024 for good cause or in the case of
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`joinder. 37 C.F.R. § 42.100. Meanwhile, the pending Apple case is on track for trial
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`in March 2023. Thus, trial in the district court litigation will occur months before the
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`deadline for a final written decision, which weighs against institution. See Fintiv I at
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`9 (“If the court’s trial date is earlier than the projected statutory deadline, the Board
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`generally has weighed this fact in favor of exercising authority to deny institution
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`under NHK.”); Fintiv II at 13 (finding this factor weighed in favor of discretionary
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`5
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`IPR2022-00351 (’842 Patent)
`Patent Owner Preliminary Response
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`denial and denying institution where the district court trial was scheduled to occur
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`two months before the deadline for the Board to reach a final written decision).
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`Petitioner argues that this factor weighs against a discretionary denial because
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`the district court has not set a trial date. Petition at 12. But under the scheduling
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`order, pretrial disclosures (jury instructions, exhibits lists, witness lists, discovery
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`and deposition designations) are due on December 20, 2022. Ex. 2002 at 4. And the
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`joint pretrial order and pretrial submissions are due on February 7, 2023. Id. Further,
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`in the related Google case (which is set on the same schedule as the Apple case), jury
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`selection has been set for February 27, 2023. It is thus reasonably certain that the
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`trial will be set for some time in March 2023. See, e.g., Ex. 2013 at 4 (Google case
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`Scheduling Order with same deadlines setting trial for February 27, 2023); Ex. 2006
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`at 4-5 (Scheduling Order setting trial for 6 weeks after deadline to file joint pretrial
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`order and pretrial submissions); Ex. 2007 at 3-4 (same).
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`The Sand Revolution decision cited by Petitioner is easily distinguishable. In
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`that case, the Board found that the trial date was uncertain primarily due to the fact
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`that the parties had jointly moved to extend the scheduling order deadlines, including
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`the trial date, multiple times. Sand Revolution II LLC v. Continental Intermodal
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`Group – Trucking LLC, IPR2019-01393, Paper 24 at 8–9 (PTAB June 16, 2020).
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`The district court in Sand Revolution had also included the qualifier “or as available”
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`for each calendared trial date, adding further uncertainty. Id. at 9. The Board thus
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`6
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`IPR2022-00351 (’842 Patent)
`Patent Owner Preliminary Response
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`concluded that this factor weighed “marginally in favor of not exercising discretion
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`to deny institution.” Id. at 9–10. But here, the parties have not sought any extensions
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`of the scheduling order deadlines. Indeed, Judge Albright’s standing order governing
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`proceedings in patent cases expressly states “[a]fter the trial date is set, the Court
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`will not move the trial date except in extreme situations.” Ex. 2008 at 6 (emphasis
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`added). And, the trial date has been set in the related Google case. Sand Revolution
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`is thus inapposite.
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`Because the district court trial is expected to occur before the deadline for a
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`final written decision in this matter, this factor weighs in favor of a discretionary
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`denial. Fintiv II at 13.
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`C.
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`Factor 3: By the time an institution decision is reached, the parties
`and the court will have completed claim construction and discovery
`will be nearly closed.
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`This factor relates to the “amount and type of work already completed in the
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`parallel litigation by the court and the parties at the time of the institution decision.”
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`Fintiv I at 9 (emphasis added). For example, “if, at the time of the institution
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`decision, the district court has issued substantive orders related to the patent at issue
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`in the petition,” this factor favors denial. Id. at 9–10. Claim construction orders
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`entered by the district court likewise “indicate that the court and parties have
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`invested sufficient time in the parallel proceeding to favor denial.” Id. at 10.
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`7
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`IPR2022-00351 (’842 Patent)
`Patent Owner Preliminary Response
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`Here, the district court has entered a scheduling order that includes all the
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`deadlines leading up to trial. The parties have already exchanged preliminary
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`infringement and invalidity contentions—including Apple’s 5 invalidity contention
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`claim charts totaling more than 260 pages for the ’842 patent alone. Further, by the
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`August 9, 2022 institution decision deadline, the parties will have exchanged final
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`infringement and invalidity contentions, discovery will nearly be closed, and, more
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`importantly, claim construction will be completed. Ex. 2015. As of the date of this
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`response, the parties have completed their claim construction briefing. The Markman
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`hearing is set for May 23, 2022, and Judge Albright typically provides preliminary
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`claim constructions at the hearing, then enters a final claim construction order within
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`a couple weeks after the hearing. See, e.g., Ex. 2009 at 2 (August 30, 2020 Claim
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`Construction Order entering constructions provided at Markman hearing held on
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`August 14, 2020). Thus, the parties and the court will have invested significant time
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`and resources in the litigation by the time the Board reaches an institution decision
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`in this matter. This favors discretionary denial. Fintiv I at 10; Fintiv II at 13–14
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`(finding that “the level of investment and effort already expended on claim
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`construction and invalidity contentions” favored denial where, as here, the parties
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`had exchanged final contentions, a Markman hearing was held, the court had entered
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`a claim construction order).
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`8
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`IPR2022-00351 (’842 Patent)
`Patent Owner Preliminary Response
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`Petitioner’s assertion that the investment in the district court case “has been
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`minimal” (Petition at 12) is without merit. Those arguments are based on the filing
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`date of its petition, rather than the date of institution, and should thus be rejected.
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`See Fintiv I at 9.
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`D.
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`Factor 4: There is complete overlap between this IPR and the
`district court proceedings.
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`This factor looks at “whether all or some of the claims challenged in the
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`petition are also at issue in district court,” and whether the “petition includes the
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`same or substantially the same claims, grounds, arguments, and evidence” as the
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`parallel district court case. Fintiv I at 12–13.
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`Here, Petitioner has challenged the exact same set of claims that are being
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`litigated in the district court. Patent Owner’s infringement contentions in the district
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`court identify claims 1, 2, 5, 6, 7, 14, 15, 16, 19, and 20 as the asserted claims for
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`the district court case, and the petition challenges these same claims. Ex. 2010 at 2.
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`Further, Petitioner’s invalidity contentions in the district court case identify
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`the same Suzuki and Park references asserted in the petition as prior art that
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`anticipates and/or renders obvious the asserted claims. Ex. 2011 at 25. Thus, there is
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`also complete overlap with respect to Petitioner’s invalidity arguments and evidence.
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`Indeed, Petitioner’s invalidity contentions in the district court case expressly
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`“incorporate[] by reference in their entirety and expressly reserves the right to
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`9
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`IPR2022-00351 (’842 Patent)
`Patent Owner Preliminary Response
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`rely upon invalidity expert reports, including all invalidity positions, invalidity
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`charts and all prior art cited therein, as well as invalidity contentions presented
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`by any present or former defendant in any of Scramoge’s or its predecessors’
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`lawsuits or by potential or actual licensees to the asserted patents, including any
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`reexamination or other post-grant review, involving the asserted patents . . . .”2
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`Id. at 9. That the district court case involves additional prior art references not
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`asserted in this IPR is “not relevant to the question of the degree of overlap for this
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`factor.” Fintiv II at 15.
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`In sum, this IPR and the district court case involve the same claims—which
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`will be construed under the same Phillips standard—and the same prior art (and, as
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`discussed below, the same parties), which raises substantial “concerns of
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`inefficiency and the possibility of conflicting decisions.” Fintiv I at 12. This factor
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`2 Though Petitioner had served its invalidity contentions at the time the petition was
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`filed, notably, Petitioner did not dispute that it intends to raise the same invalidity
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`arguments and evidence in the district court. Petition at 13. Nor can it in light of this
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`express incorporation by reference.
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`10
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`thus weighs in favor of a discretionary denial. See Fintiv II at 15; NHK Spring at 19–
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`IPR2022-00351 (’842 Patent)
`Patent Owner Preliminary Response
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`20.3
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`E.
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`Factor 5: Petitioner is a defendant in the district court litigation.
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`There is no dispute that Petitioner is the defendant in the district court
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`litigation. “Because the petitioner and the defendant in the parallel proceeding are
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`the same party, this factor weighs in favor of discretionary denial.” Fintiv II at 15.
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`Petitioner asserts that the Board should simply ignore this factor because
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`“most Petitioners in IPR proceedings” are also defendants in district court litigation.
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`Petition at 13. This argument is without support and contrary to precedent, and
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`should thus be rejected. Fintiv requires due consideration of this factor, regardless
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`of how common it is for the Petitioner to also be a defendant in the litigation.
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`F.
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`Factor 6: The petition is without merit and unlikely to succeed.
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`The Board may consider other circumstances in the exercise of its discretion,
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`including the merits of the case. Fintiv I at 14. However, “a full analysis of the merits
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`is not necessary to evaluate this factor.” Fintiv II at 17. In the event the Board finds
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`3 Indeed, this case presents a clearer case for discretionary denial than others where
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`there was a lesser degree of overlap. See, e.g., Next Caller Inc. v. TRUSTID, Inc.,
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`IPR2019-00961, Paper 10 at 14 (PTAB October 16, 2019) (denying institution
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`where the district court case involved only a subset of the challenged claims).
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`11
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`IPR2022-00351 (’842 Patent)
`Patent Owner Preliminary Response
`
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`that Petitioner has made a preliminary showing for only a subset of the challenged
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`claims, it should exercise its discretion to deny institution. See Chevron Oronite Co.
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`LLC v. Infineum USA L.P., IPR2018-00923, Paper 9 (PTAB Nov. 7, 2018) (decision
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`denying institution of IPR where Petitioner met reasonable likelihood for insufficient
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`number of challenged claims); Deeper, UAB v. Vexilar, Inc., IPR2018-01310, Paper
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`7 (PTAB Jan. 24, 2019) (same).
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`III. CONCLUSION
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`As set forth above, all six Fintiv factors weigh against institution. The district
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`court trial will precede any final written decision from the Board by five months. To
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`avoid duplication of efforts, wasting resources, and potentially inconsistent
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`decisions, the Board should deny institution.
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`Date: May 9, 2022
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`Respectfully submitted,
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`By: /Brett Cooper/
`Brett Cooper, Reg. No. 55,085
`bcooper@raklaw.com
`rak_scramoge@raklaw.com
`Reza Mirzaie, Reg. No. 69,138
`rmirzaie@raklaw.com
`Russ, August & Kabat
`12424 Wilshire Blvd. 12th Floor
`Los Angeles, CA 90025
`Tel.: 310-826-7474
`Fax: 310-826-6991
`
`Counsel for Patent Owner,
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`12
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`IPR2022-00351 (’842 Patent)
`Patent Owner Preliminary Response
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`Scramoge Technology, Ltd.
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`13
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`IPR2022-00351 (’842 Patent)
`Patent Owner Preliminary Response
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`CERTIFICATION REGARDING WORD COUNT
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`Pursuant to 37 C.F.R. §42.24(d), Patent Owner hereby certifies, in accordance
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`with and reliance on the word count provided by the word-processing system used
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`to prepare this PATENT OWNER’S PRELIMINARY RESPONSE, that the
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`words in this paper is 2,721. Pursuant to 37 C.F.R. § 42.24, this word count is in
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`compliance with the word limit set forth in 37 C.F.R. § 42.24(b)(1) excluding the
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`portions exempted under 37 C.F.R. § 42.24(a)(1).
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`Respectfully submitted,
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`By: /Brett Cooper/
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`Brett Cooper, Reg. No. 55,085
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`Date: May 9, 2022
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`IPR2022-00351 (’842 Patent)
`Patent Owner Preliminary Response
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`CERTIFICATE OF SERVICE (37 C.F.R. § 42.6(e)(1))
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`The undersigned hereby certifies that the above document was served on May
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`9, 2022 by filing this document through the Patent Trial and Appeal Board End to
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`End system, as well as delivering a copy via electronic mail upon the following
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`attorneys of record for the Petitioner:
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`Scott T. Jarratt (Reg No. 70,297)
`scott.jarratt.ipr@haynesboone.com
`Andrew S. Ehmke (Reg No. 50,271)
`andy.ehmke.ipr@haynesboone.com
`Calmann J. Clements (Reg No. 66,910)
`calmann.clements.ipr@haynesboone.com
`HAYNES AND BOONE, LLP
`2323 Victory Ave. Suite 700
`Dallas, TX 75219
`Phone: (972) 739-8663
`Fax: (214) 200-0853
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`/Brett Cooper/
`Brett Cooper, Reg. No. 55,085
`bcooper@raklaw.com
`rak_scramoge@raklaw.com
`Russ, August & Kabat
`12424 Wilshire Blvd. 12th Floor
`Los Angeles, CA 90025
`Tel.: 310-826-7474
`Fax: 310-826-6991
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