`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`AMAZON.COM, INC., AMAZON.COM SERVICES, LLC,
`AMAZON WEB SERVICES, INC,
`and T-MOBILE USA, INC.,
`Petitioners,
`
`v.
`
`VOIP-PAL.COM, INC.,
`Patent Owner.
`
`
`
`Case IPR2022-01181
`U.S. Patent No. 10,880,721
`
`
`
`
`PETITIONERS’ MOTION FOR JOINDER
`
`
`
`
`
`
`
`
`
`I.
`
`STATEMENT OF PRECISE RELIEF REQUESTED
`
`Pursuant to 35 U.S.C. § 315(c) and 37 C.F.R. § 42.122(b), Petitioners move
`
`Motion for Joinder
`IPR2022-01181
`
`for joinder with any Inter Partes Review instituted in Google LLC v. VoIP-Pal,
`
`Inc., IPR2022-01075 (“the 1075 proceeding”), filed on June 3, 2022, for U.S. Pa-
`
`tent No. 10,880,721 (“the ’721 patent”). See IPR2022-01075, Paper 1. This mo-
`
`tion is timely because it is being filed before institution of the 1075 proceeding.
`
`Petitioners request that action on this motion be held in abeyance until, and the mo-
`
`tion be granted only if, an IPR is instituted in the 1075 proceeding. See Central
`
`Security Group-Nationwide, Inc. v. Ubiquitous Connectivity, LP, IPR2019-01610,
`
`Paper 12, at 8-9 (PTAB Feb. 26, 2020) (approving pre-institution joinder motion
`
`that asked that motion be held in abeyance until after institution). Petitioners have
`
`consulted with counsel for the petitioner in the 1075 proceeding (hereinafter
`
`“Google”), and Google does not oppose Petitioners’ request for joinder.
`
`Petitioners request institution of the Petition for Inter Partes Review being
`
`filed concurrently herewith (“Petition”). The Petition is materially the same as the
`
`petition filed in the 1075 proceeding (“Google’s Petition”). The Petition and the
`
`Google Petition challenge the same claims, on the same grounds, and rely on the
`
`same prior art and evidence, including an identical declaration from the same
`
`expert.1
`
`
`1 The declaration is a duplicate of the declaration filed in IPR2022- 01075.
`
`
`
`1
`
`
`
`
`
`Motion for Joinder
`IPR2022-01181
`
`Petitioners agree to proceed solely on the grounds, evidence, and arguments
`
`advanced, or that will be advanced, in the 1075 proceeding as instituted. Thus, the
`
`Petition warrants institution under 35 U.S.C. § 314, and 35 U.S.C. § 315(c) permits
`
`Petitioners’ joinder to any IPR instituted in the 1075 proceeding.
`
`Further, upon joining the 1075 proceeding, Petitioners will act as “under-
`
`studies” and will not assume an active role unless Google ceases to participate in
`
`the 1075 proceeding. Google will maintain the lead role in the proceeding so long
`
`as it is a party to the proceeding. These limitations will avoid lengthy and duplica-
`
`tive briefing. Also, Petitioners will not seek additional depositions or deposition
`
`time. Petitioners agree to the foregoing conditions even in the event that other
`
`IPRs filed by other, third-party petitioners are joined with the 1075 proceeding.
`
`Accordingly, the proposed joinder will neither unduly complicate the 1075 pro-
`
`ceeding nor delay its schedule.
`
`In fact, joinder will help efficiently resolve the disputes among the parties.
`
`By joinder, a single Board decision may dispose of the issues raised in the 1075
`
`proceeding for all interested parties. Further, joinder will narrow the issues in the
`
`co-pending district court actions. See 35 U.S.C. § 315(e)(2). Finally, joinder
`
`would not complicate or delay the 1075 proceeding and would not adversely affect
`
`any schedule set in that proceeding. In sum, joinder would promote efficient adju-
`
`dication in multiple forums.
`
`
`
`2
`
`
`
`
`
`Motion for Joinder
`IPR2022-01181
`
`Joinder will not unduly prejudice any party. Because joinder will not add
`
`any new substantive issues, delay the schedule, burden deponents, or increase
`
`needless filings, any additional costs on the Patent Owner would be minimal. On
`
`the other hand, denial of joinder would prejudice Petitioners. Their interests may
`
`not be adequately protected in the 1075 proceeding, particularly if Google settles
`
`with the Patent Owner. Petitioners should be allowed to join in a proceeding af-
`
`fecting a patent asserted against them.
`
`II. BACKGROUND AND RELATED PROCEEDINGS
`
`VoIP-Pal.com, Inc. (“Patent Owner”) is the owner of the ’721 patent. The
`
`’721 patent is the subject of the following actions:
`
`Case No.
`VoIP-Pal.com, Inc. v.
`Amazon.com, Inc., et al., Case
`No. 6:21-cv-00668
`VoIP-Pal.com, Inc. v. T-
`Mobile USA, Inc., Case No.
`6:21-cv-00674
`VoIP-Pal.com, Inc. v. Meta
`Platforms, Inc., et al., Case
`No. 3:22-cv-03202
`
`Jurisdiction
`Western District of
`Texas
`
`Western District of
`Texas
`
`Northern District of
`California
`
`VoIP-Pal.com, Inc. v. Google,
`LLC f/k/a Google Inc., Case
`No. 3:22-cv-03199
`
`Northern District of
`California
`
`
`
`3
`
`Status
`Litigation is pending.
`
`Litigation is pending.
`
`Litigation is pending.
`Transferred from the
`Western District of
`Texas, Case No. 6:21-
`cv-00665.
`Litigation is pending.
`Transferred from the
`Western District of
`Texas, formerly Case
`No. 6:21-cv-00667.
`
`
`
`
`
`Case No.
`VoIP-Pal.com, Inc. v. Apple
`Inc., Case No. 6:21-cv-00670
`VoIP-Pal.com, Inc. v. AT&T
`Corp., et al., Case No. 6:21-
`cv-00671
`VoIP-Pal.com, Inc. v. Verizon
`Communications Inc., et al.,
`Case No. 6:21-cv-00672
`VoIP-Pal.com, Inc. v.
`Samsung Electronics Co.,
`Ltd., et al., Case No. 6:21-cv-
`01246
`
`Motion for Joinder
`IPR2022-01181
`
`Jurisdiction
`Western District of
`Texas
`Northern District of
`California
`
`Status
`Litigation was
`terminated.
`Litigation was
`terminated.
`
`Western District of
`Texas
`
`Western District of
`Texas
`
`Litigation is pending.
`
`Litigation is pending.
`Transferred from
`Austin division to
`Waco division,
`formerly Case No.
`1:21-cv-01084 (W.D.
`Tex.).
`Litigation is pending.
`Transferred from
`Austin division to
`Waco division,
`formerly Case No.
`1:21-cv-01085 (W.D.
`Tex.).
`Litigation was
`terminated.
`
`Litigation was
`terminated.
`Litigation is pending.
`
`VoIP-Pal.com, Inc. v. Huawei
`Technologies Co., Ltd., et al.,
`Case No. 6:21-cv-01247
`
`Western District of
`Texas
`
`Northern District of
`California
`
`Northern District of
`California
`Northern District of
`California
`
`AT&T Corp., et al. v. VoIP-
`Pal.com, Inc., Case No. 3:21-
`cv-05078
`Apple Inc. v. VoIP-Pal.com,
`Inc., Case No. 3:21-cv-05110
`Cellco Partnership d/b/a
`Verizon Wireless Inc., et al. v.
`VoIP-Pal.com, Inc., Case No.
`3:21-cv-05275
`Twitter, Inc. v. VoIP-Pal.com,
`Inc., Case No. 3:21-cv-09773
`
`
`
`
`4
`
`Northern District of
`California
`
`Litigation is pending.
`
`
`
`
`
`Motion for Joinder
`IPR2022-01181
`III. STATEMENT OF REASONS FOR THE REQUESTED RELIEF
`A.
`
`Legal Standards and Applicable Rules
`
`The Board has discretion to join a properly filed IPR petition to an IPR pro-
`
`ceeding. 35 U.S.C. § 315(c); 37 C.F.R. § 42.122(b); see also Dell Inc. v. Network-
`
`1 Sec. Solutions, Inc., IPR2013-00385, Paper 17, at 4-6 (PTAB July 29, 2013);
`
`Sony Corp. v. Yissum Res. & Dev. Co. of the Hebrew Univ. of Jerusalem, IPR2013-
`
`00326, Paper 15, at 3-4 (PTAB Sept. 24, 2013); Microsoft Corp. v. Proxyconn,
`
`Inc., IPR2013-00109, Paper 15, at 3-4 (PTAB Feb. 25, 2013). “The Board will de-
`
`termine whether to grant joinder on a case-by-case basis, taking into account the
`
`particular facts of each case, substantive and procedural issues, and other consider-
`
`ations.” Dell, IPR2013-00385, Paper 17, at 3. The movants bear the burden of
`
`proof in establishing entitlement to the requested relief. 37 C.F.R. §§ 42.20(c),
`
`42.122(b). A motion for joinder should:
`
`(1) set forth the reasons why joinder is appropriate; (2) identify any
`
`new grounds of unpatentability asserted in the petition; (3) explain
`
`what impact (if any) joinder would have on the trial schedule for the
`
`existing review; and (4) address specifically how briefing and discov-
`
`ery may be simplified.
`
`Dell, IPR2013-00385, Paper 17, at 4.
`
`
`
`5
`
`
`
`
`
`Motion for Joinder
`IPR2022-01181
`
`B.
`
`Joinder with the 1075 Proceeding Is Appropriate
`
`The Board “routinely grants motions for joinder where the party seeking
`
`joinder introduces identical arguments and the same grounds raised in the existing
`
`proceeding.” Samsung Elecs. Co., Ltd. v. Raytheon Co., IPR2016-00962, Paper
`
`12, at 9 (PTAB Aug. 24, 2016) (internal quotations and citations omitted). Here,
`
`joinder with the 1075 proceeding is appropriate because the present Petition intro-
`
`duces identical arguments and the same grounds raised in the existing 1075 pro-
`
`ceeding (i.e., they contain the same grounds, based on the same prior art combina-
`
`tions and supporting evidence, against the same claims). Indeed, there are no
`
`changes to the facts, evidence, or arguments used by Google’s Petition in the 1075
`
`proceeding in demonstrating satisfaction of the implicated claims by the applied
`
`prior art. Because these proceedings introduce identical arguments and the same
`
`grounds, good cause exists for joining this proceeding with the 1075 proceeding so
`
`that the Board, consistent with 37 C.F.R. § 42.1(b), can efficiently “secure the just,
`
`speedy, and inexpensive resolution” of the present and 1075 proceeding.
`
`C.
`
`Joinder Will Not Add Any New Grounds of Unpatentability or Have an
`Impact on the Trial Schedule
`
`The Petition is based on the same grounds and combinations of prior art in
`
`Google’s Petition in the 1075 proceeding. For simplicity and efficiency, Petition-
`
`ers have copied the substance of Google’s Petition and have relied on the same ac-
`
`companying declaration. Petitioners do not seek to introduce grounds or claims
`
`
`
`6
`
`
`
`
`
`Motion for Joinder
`IPR2022-01181
`
`not in the 1075 proceeding and seek only to join the proceeding as instituted. Peti-
`
`tioners are using the same expert and have submitted an identical declaration as in
`
`the 1075 proceeding. The Patent Owner should not require any discovery beyond
`
`that which it may need in the 1075 proceeding—nor should the Board permit any.
`
`The present Petition introduces no new substantive issues relative to the 1075 pro-
`
`ceeding and does not seek to broaden the scope of the 1075 proceeding.
`
`Joinder will not impact the 1075 proceeding trial schedule because the pre-
`
`sent Petition presents no new issues or grounds of unpatentability. See LG,
`
`IPR2015-01353, Paper 11, at 6 (granting IPR and motion for joinder where “join-
`
`der should not necessitate any additional briefing or discovery from Patent Owner
`
`beyond that already required in [the original IPR]”). Further, Petitioners explicitly
`
`consent to any trial schedule adopted in the 1075 proceeding. There are no new
`
`issues for the Board to address, and Patent Owner will not be required to present
`
`any additional responses or arguments.
`
`The Patent Owner’s Response will also not be negatively impacted because
`
`the issues presented in the present Petition are identical to the issues presented in
`
`the 1075 proceeding. Patent Owner will not be required to provide any additional
`
`analysis or arguments beyond what it will already provide in responding to
`
`Google’s Petition in the 1075 proceeding. Also, because the present Petition relies
`
`
`
`7
`
`
`
`
`
`Motion for Joinder
`IPR2022-01181
`
`on the same expert and the same declaration, only a single deposition is needed for
`
`the proposed joined proceeding.
`
`Accordingly, joinder with the 1075 proceeding does not unduly burden or
`
`negatively impact the trial schedule.
`
`D.
`
`Procedures to Simplify Briefing and Discovery
`
`Petitioners explicitly agree to take an “understudy” role, which will simplify
`
`briefing and discovery. Specifically, Petitioners explicitly agree, upon joining the
`
`1075 proceeding, that the following conditions, as previously approved by the
`
`Board in similar circumstances, shall apply so long as Google remains an active
`
`party:
`
`a) all filings by Petitioners in the joined proceeding will be
`
`consolidated with the filings of Google, unless a filing concerns
`
`issues solely involving Petitioners;
`
`b) Petitioners shall not be permitted to raise any new grounds not
`
`already instituted by the Board in the 1075 proceeding, or
`
`introduce any argument or discovery not already introduced by
`
`Google;
`
`c) Petitioners shall be bound by any agreement between Patent
`
`Owner and Google concerning discovery and/or depositions; and
`
`
`
`8
`
`
`
`
`
`Motion for Joinder
`IPR2022-01181
`
`d) Petitioners shall not receive any direct, cross examination, or
`
`redirect time at deposition beyond that permitted under either 37
`
`C.F.R. § 42.53 or any agreement between Patent Owner and
`
`Google.
`
`See Noven Pharmaceuticals, Inc. v. Novartis AG, IPR2014-00550, Paper 38, at 5
`
`(PTAB Apr. 10, 2015). Unless and until Google ceases to participate, Petitioners
`
`will not assume an active role therein.
`
`Thus, by Petitioners accepting an “understudy” role, the parties can comply
`
`with the trial schedule assigned to the 1075 proceeding without needing any
`
`duplicative efforts by the Board or the Patent Owner. These steps minimize the
`
`possibility of any complication or delay from joinder. See LG, IPR2015-01353,
`
`Paper 11, at 6-7 (granting IPR and motion for joinder because “joinder would
`
`increase efficiency by eliminating duplicative filings and discovery, and would
`
`reduce costs and burdens on the parties as well as the Board” where petitioners
`
`agreed to an “understudy” role). Petitioners are further willing to agree to any
`
`other reasonable conditions the Board deems necessary.
`
`IV. GENERAL PLASTIC IS INAPPLICABLE
`
`Petitioners note that the Board has indicated that the factors outlined by
`
`General Plastic are not relevant “where a different petitioner files a ‘me-too’ or
`
`‘copycat’ petition in conjunction with a timely motion to join.” See, e.g., Celltrion,
`
`
`
`9
`
`
`
`
`
`Motion for Joinder
`IPR2022-01181
`
`Inc. v. Genentech, Inc., IPR2018-01019, Paper 11, at 9-11 (PTAB Oct. 30, 2018);
`
`Pfizer, Inc. v Genentech, Inc., IPR2017-02063, Paper 25, at 7-8 (PTAB Feb. 21,
`
`2018). Through this motion to join and corresponding Petition, Petitioners have
`
`not modified the positions advanced in the 1075 proceeding. See, e.g., Celltrion,
`
`IPR2018-01019, Paper 11, at 10-11 (finding petitioner’s “copycat” petition and
`
`motion to join an instituted IPR to “effectively obviate[] any concerns of serial
`
`harassment and unnecessary expenditure of resources,” even though petitioner
`
`“previously filed two petitions directed to the same claims of the same patent.”).
`
`Rather, through grant of this joinder, Petitioners merely seek to ensure that the
`
`1075 proceeding is not prematurely terminated based on opportunistic settlement
`
`by Patent Owner with fewer than all parties against which it has asserted the
`
`subject patent. As such, Petitioners respectfully submit that General Plastic does
`
`not apply in this circumstance.
`
`In the event the Board does analyze the General Plastic factors, those factors
`
`heavily weigh in favor of instituting the present IPR. General Plastic Indus. Co.,
`
`Ltd. v. Canon Kabushiki Kaisha, IPR2016-01357, Paper 19, at 16 (PTAB Sept. 6,
`
`2017) (precedential as to § II.B.4.i).
`
`The first factor is whether the same petitioner previously filed a petition
`
`directed to the same claims of the same patent. Petitioners have not previously
`
`filed a petition against the ’721 patent (Petitioners are concurrently filing a second
`
`
`
`10
`
`
`
`
`
`Motion for Joinder
`IPR2022-01181
`
`petition on the ’721 patent following Google’s own division of the challenged
`
`claims across two separate petitions, which is necessary in view of the number of
`
`claims asserted by Patent Owner). Accordingly, this factor weighs in favor of
`
`institution.
`
`The second factor is whether at the time of filing the first petition the
`
`petitioner knew or should have known of the prior art asserted in the second
`
`petition. This factor is neutral, if not inapplicable, in the General Plastic analysis.
`
`Here, Google’s Petition and Petitioners’ Petition share the same prior art because
`
`Petitioners’ Petition is a “copy” of Google’s petition. Because Petitioners are
`
`merely seeking to join in an understudy role, the factor is neutral, at best, in
`
`determining whether to institute.
`
`The third factor is whether at the time of filing of the second petition the
`
`petitioner already received the patent owner’s preliminary response to the first
`
`petition or received the Board’s decision on whether to institute review in the first
`
`petition. The Board has not yet entered its decision to institute review on the 1075
`
`proceeding. In addition, because the present Petition is essentially a copy of the
`
`prior Google Petition and submitted with a motion for joinder stating that
`
`Petitioners will serve an understudy role, the Petition is not an attempt to harass the
`
`Patent Owner or otherwise engage in serial, tactical filings. Thus, this factor
`
`weighs in favor of joinder.
`
`
`
`11
`
`
`
`
`
`Motion for Joinder
`IPR2022-01181
`
`The fourth factor is the length of time elapsed between the time the
`
`petitioner learned of the prior art asserted in the second petition and filing of the
`
`second petition, and the fifth factor is whether the petitioner provides adequate
`
`explanation for the time elapsed between the filings of multiple petitions directed
`
`to the same claims of the same patent. Petitioners filed their Petition and this
`
`joinder motion within weeks of Google’s Petition and well within the time period
`
`allowed under 35 U.S.C. § 315(c) and 37 C.F.R. § 42.122(b). In the context of a
`
`joinder motion where Petitioners will be taking an understudy role, the fourth and
`
`fifth factors are therefore inapplicable.
`
`The sixth factor is the finite resources of the Board. Allowing Petitioners’
`
`joinder motion where Petitioners will serve in an understudy role will not impact
`
`the Board’s resources beyond those resources the Board dedicates to the instant
`
`joinder motion.
`
`The seventh factor is the requirement under 35 U.S.C. § 316(a)(11) to issue
`
`a final determination not later than one year after the date on which the Director
`
`notices institution of review. As noted above, joining Petitioners should not
`
`impact the schedule, particularly because this motion is filed prior to institution of
`
`the 1075 proceeding. Accordingly, this factor weighs in favor of institution.
`
`An eighth factor identified by the Board in Shenzhen is the extent to which
`
`the petitioner and any prior petitioner(s) were similarly situated defendants or
`
`
`
`12
`
`
`
`
`
`Motion for Joinder
`IPR2022-01181
`
`otherwise realized a similar-in-time hazard regarding the challenged patent.
`
`Shenzhen Silver Star Intelligent Tech. Co., Ltd. v. iRobot Corp., IPR2018-00898,
`
`Paper 9, at 7, 13-14 (PTAB Oct. 1, 2018) (noting “the purpose of proposed Factor
`
`8 is to discourage tactical filing of petitions over time by parties that faced the
`
`same threat at the same time” such that earlier petitions are filed as “test case(s)” to
`
`gain “tactical advantage”). Because the Petition does not introduce any new
`
`grounds of unpatentability, was filed within weeks of Google’s Petition and well
`
`before institution of the 1075 proceeding, and will effectively merge into a single
`
`proceeding with the 1075 proceeding, no such tactical advantage is gained here.
`
`Thus, none of the General Plastic factors weighs against institution and
`
`joinder in this situation.
`
`V. CONCLUSION
`
`Joinder will not affect the substance, procedure, or scheduling of the 1075
`
`proceeding. Petitioners file this motion under the statutory joinder provisions as
`
`contemplated by the AIA. Joinder will simplify the issues and promote efficiency,
`
`justice, and speed.
`
`For the foregoing reasons, Petitioners respectfully request inter partes re-
`
`view of U.S. Patent No. 10,880,721 and joinder with Google LLC v. VoIP-Pal,
`
`Inc., IPR2022-01075.
`
`
`
`13
`
`
`
`
`
`
`
`Dated: June 27, 2022
`
`PERKINS COIE LLP
`1900 Sixteenth Street, Suite 1400
`Denver, Colorado 80202
`Phone: 303-291-2300
`Fax: 303-291-2400
`
`Motion for Joinder
`IPR2022-01181
`
`
`
`Respectfully submitted,
`
`/Kourtney Mueller Merrill/
`Lead Counsel
`Kourtney Mueller Merrill, Reg. No. 58,195
`
`Backup Counsel
`
`Daniel T. Shvodian, Reg. No. 42,148
`Amanda Tessar, Reg. No. 53,683
`Christopher L. Kelley, Reg. No. 42,714
`
`Counsel for Petitioners
`
`
`
`
`
`(Control No. IPR2022-01181)
`
`
`
`14
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on June 27, 2022, I caused a true and correct copy of the
`
`Motion for Joinder
`IPR2022-01181
`
`foregoing PETITIONERS’ MOTION FOR JOINDER to be served via USPS
`
`Priority Mail Express on the Patent Owner at the following correspondence address
`
`of record as listed on PAIR:
`
`THORPE NORTH & WESTERN, LLP.
`P.O. Box 1219
`SANDY UT 84091-1219
`
`A courtesy copy was also sent via electronic mail to the Patent Owner’s
`
`
`
`litigation counsel at the following email addresses:
`
`
`
`Dated: June 27, 2022
`
`PERKINS COIE LLP
`1900 Sixteenth Street, Suite 1400
`Denver, Colorado 80202
`Phone: 303-291-2300
`Fax: 303-291-2400
`
`Lewis E. Hudnell, III, lewis@hudnellaw.com
`Nicolas S. Gikkas, nick@hudnelllaw.com
`Hudnell Law Group P.C.
`800 W. El Camino Real Suite 180
`Mountain View, California 94040
`
`Respectfully submitted,
`
`/Kourtney Mueller Merrill/
`Lead Counsel
`Kourtney Mueller Merrill, Reg. No. 58,195
`
`Backup Counsel
`
`Daniel T. Shvodian, Reg. No. 42,148
`Amanda Tessar, Reg. No. 53,683
`Christopher L. Kelley, Reg. No. 42,714
`
`Counsel for Petitioners
`
`
`
`
`
`
`
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