UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`APPLE INC.,
`Petitioner,
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`v.
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`JAWBONE INNOVATIONS, LLC,
`Patent Owner.
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`Case IPR2022-01243
`Patent No. 8,280,072
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`PETITIONER’S MOTION FOR JOINDER UNDER
`35 U.S.C. § 315(c), 37 C.F.R. § 42.22, AND § 42.122(b)
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`APPLE INC.,
`Petitioner,
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`v.
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`JAWBONE INNOVATIONS, LLC,
`Patent Owner.
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`Case IPR2022-01243
`Patent No. 8,280,072
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`PETITIONER’S MOTION FOR JOINDER UNDER
`35 U.S.C. § 315(c), 37 C.F.R. § 42.22, AND § 42.122(b)
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`Case IPR2022-01243
`Attorney Docket No: 50095-0092IP1
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`STATEMENT OF PRECISE RELIEF REQUESTED
`Apple Inc. (“Apple”) respectfully submits this Motion for Joinder,
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`I.
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`concurrently with a Petition (“Apple’s Petition”) for inter partes review of U.S.
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`Patent No. 8,280,072 (“the ’072 Patent”).
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` Pursuant to 35 U.S.C. § 315(c) and 37 C.F.R. §§ 42.22 and 42.122(b), Apple
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`requests institution of an inter partes review and joinder with IPR2022-00213
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`(“Samsung IPR”), which was instituted on June 8, 2022. Samsung Electronics Co.
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`Ltd. et al. v. Jawbone Innovations, LLC, IPR2022-00213, Paper 10 (PTAB June 8,
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`2022). Apple’s Petition is substantively the same as the Samsung IPR petition. It
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`challenges the same claims, on the same grounds, relies on the same prior art as
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`instituted in the Samsung IPR, and relies on the same expert declaration. Therefore,
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`joinder would create no additional burden for the Board, the Samsung IPR Petitioner
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`(“Samsung”), or Patent Owner if joined. Joinder would therefore lead to an efficient
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`resolution of the validity of the ’072 Patent.
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`Apple is currently a defendant in a district court litigation in the Western
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`District of Texas, Case No. 6:21-cv-00984 (W.D. Tex.). In that proceeding, Apple
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`has been accused of infringing the ’072 Patent. Apple has not previously filed a
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`petition for IPR challenging the validity of the ’072 Patent.1
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`1 Apple is concurrently filing a second petition for IPR against the ’072 Patent on
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`Apple stipulates that if joinder is granted, it will act as an “understudy” and
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`will not assume an active role unless Samsung ceases to participate in the
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`proceeding. Samsung will maintain the lead role in the proceeding so long as it
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`remains in the proceeding. These limitations will avoid lengthy and duplicative
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`briefing. Apple also will not seek additional depositions or deposition time. Joinder
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`will not impact the trial schedule because the proceeding based on the Samsung IPR
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`is in its early stages, having just instituted on June 8, 2022.
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`In fact, joinder will help efficiently resolve the disputes among the parties. By
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`joinder, a single Board decision may dispose of the issues raised in the Samsung IPR
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`for all interested parties.
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`Joinder will not unduly prejudice any party. Because joinder will not add any
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`new substantive issues, delay the schedule, burden deponents, or needlessly increase
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`filings, any additional costs on Patent Owner will be minimal. On the other hand,
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`denial of joinder would prejudice Apple. Apple’s interests may not be adequately
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`protected in the Samsung IPR, particularly if Samsung settles with Patent Owner and
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`ceases to participate. Apple should be allowed to join in a proceeding affecting a
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`patent asserted against it.
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`Given the similarities of the proceedings, the lack of undue prejudice to Patent
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`different grounds and relying on different references. See IPR2022-01244.
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`Owner, and the potential benefit to the public and to the Board that would accrue by
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`Apple’s cooperative participation in the Samsung IPR in the event that Samsung’s
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`participation terminates, the Board should institute IPR and grant Apple’s Motion
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`for Joinder.
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`II. ARGUMENT
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`A. Legal Standards and Applicable Rules
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`A petitioner may request joinder, without prior authorization, no later than
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`one month after the institution date of the proceeding to which joinder is requested.
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`37 C.F.R. § 42.122(b); Taiwan Semiconductor Mfg. Co., Ltd. v. Zond LLC,
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`IPR2014-00781 and IPR2014-00782, Paper 5 at 3 (PTAB May 29, 2014).
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`The Board has discretion to grant a motion for joinder of a petitioner for
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`inter partes review to another inter partes review proceeding. See 35 U.S.C. §
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`315(c). In determining whether to exercise its discretion to grant a motion for
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`joinder, the Board considers: (1) reasons why joinder is appropriate; (2) any new
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`grounds of unpatentability asserted in the petition; (3) what impact (if any) joinder
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`would have on the trial schedule for the existing review; and (4) specifically how
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`briefing and discovery may be simplified. See Dell, Inc. v. Network-1 Security
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`Solutions, Inc., IPR201300385, Paper 17 at 3 (July 29, 2013).
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`B. Apple’s Motion for Joinder is Timely
`Joinder may be requested “no later than one month after the institution date
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`of any inter partes review for which joinder is requested.” 37 C.F.R. § 42.122(b).
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`The Samsung IPR was instituted on June 8, 2022. IPR2022-00213, Paper 10
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`(PTAB June 8, 2022). Apple’s current motion is timely as it is being filed within
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`one month of the institution date.
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`C. The Four Factors Favor Joinder
`Each of the four factors weighs in favor of granting Apple’s Motion for
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`Joinder. Apple’s Petition is substantively identical to the petition in the Samsung
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`IPR; it presents no new grounds of unpatentability. Joinder will have no impact
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`on the pending schedule of the Samsung IPR. Moreover, the briefing and
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`discovery will be simplified by resolving all issues in a single proceeding.
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`1.
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`Joinder of Apple Is Appropriate Because It Will Promote
`an Efficient Determination of the Validity of the ’072
`Patent Without Prejudice to Any Party
`Apple seeks to join the Samsung IPR in order to ensure that an accused
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`infringer with an active interest in the proceeding remains a party to this IPR if
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`Samsung’s participation is terminated prior to completion. Thus, joining Apple to
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`the Samsung IPR is the most practical way to secure the just, speedy, and
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`inexpensive resolution of the challenge to the ’072 Patent. See 37 C.F.R. § 42.1(b).
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`If Apple is joined as a party, the validity of the grounds raised in the
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`Samsung IPR can be determined in a single proceeding. Joinder also is appropriate
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`Case IPR2022-01243
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`because Apple’s Petition challenges the validity of the same claims of the ’072
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`Patent on identical grounds to those in the Samsung IPR. There are no substantive
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`differences between Apple’s Petition and the Samsung IPR Petition. Apple also
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`relies on the same substantive evidence in its Petition as is relied on in the Samsung
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`IPR. A consolidated proceeding, including Apple and Samsung, will therefore be
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`more efficient and less wasteful, as only a single trial on these common grounds
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`would be required. See, e.g., Oracle America Inc. v. Realtime Data LLC, IPR2016-
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`01672, Paper 13 at 7 (PTAB Mar. 7, 2017) (noting that “joining Oracle’s identical
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`challenges to those in the 1002 IPR will lead to greater efficiency while reducing
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`the resources necessary from both Realtime and the Board”). The Board “routinely
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`grants motions for joinder where the party seeking joinder introduces identical
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`arguments and the same grounds raised in the existing proceeding.” Samsung
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`Elecs. Co., Ltd. v. Raytheon Co., IPR2016- 00962, Paper 12 at 9 (PTAB Aug. 24,
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`2016) (internal quotations and citations omitted).
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`Joining Apple as a party to the Samsung IPR would promote the public
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`interest relating to the unpatentability of the ’072 Patent and not cause any undue
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`prejudice to Patent Owner or Samsung. The Patent Owner must respond to the
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`common invalidity grounds regardless of joinder.
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`2.
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`Apple’s Petition Does Not Raise Any New Grounds of
`Unpatentability and Therefore Does Not Add Additional
`Complexity to the Grounds in Samsung’s Petition
`Apple’s Petition challenges the validity of the ’072 Patent on identical
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`grounds to those in the Samsung IPR. See IPR2022-00213, Paper 3 (November
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`19, 2021). Apple’s substantive evidence―including its supporting expert
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`declaration and substantive exhibits―are identical to those presented in the
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`Samsung IPR. Further, unity of exhibits and exhibit numbering with the Samsung
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`IPR has been maintained. Accordingly, no new grounds are being introduced. See
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`Sony Corp. v. Memory Integrity, LLC, IPR2015-01353, Paper No. 11 at 5-6 (PTAB
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`Oct. 5, 2015) (granting motion for joinder where petitioners relied “on the same
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`prior art, same arguments, and same evidence”).
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`Therefore, consolidation of this proceeding with Samsung’s via joinder of
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`Apple’s Petition will not raise any new issues of unpatentability and will not
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`impose any additional burden on the Board or Patent Owner, or add additional
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`complexity to the case.
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`3.
`Joinder Will Not Affect the Schedule in the Samsung IPR
`Given that the Board recently instituted review of the Samsung IPR, joinder
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`of Apple would not affect the schedule in any forthcoming trial. Apple’s
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`participation should result in no changes to the schedule.
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`Apple agrees to adhere to all applicable deadlines set forth in the Samsung
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`IPR Scheduling Order. The Patent Owner’s Response will not be affected because
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`the issues in Apple’s Petition are identical to those in the Samsung IPR petition.
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`Patent Owner will thus not be required to provide any additional analysis or
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`arguments.
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`4.
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`Joinder Will Simplify Briefing Because Apple Has Agreed
`to Consolidated Filings and an Understudy Role if the
`Samsung Petitioner Remains
`To further prevent joinder from imposing any burden on Samsung, Patent
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`Owner, or the Board and to further ensure that there are no changes in the potential
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`trial schedule, Apple has agreed, as long as Samsung remains a party to the
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`Samsung IPR, to take an understudy role, which will simplify briefing and
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`discovery. In this role, Apple agrees to the following conditions:
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`(a) Apple shall not make any substantive filing and shall be bound by the
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`filings of Samsung, unless a filing concerns termination and settlement, or issues
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`solely involving Apple;
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`(b) Apple shall not present any argument or make any presentation at oral
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`hearing unless an issue solely involves Apple, or when addressing Board-approved
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`motions that do not affect Samsung, or its respective position;
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`(c) Apple shall not seek to cross-examine or defend the cross-
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`examination of any witness, unless the topic of cross-examination concerns issues
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`solely involving Apple;
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`(d) Apple shall not seek discovery from Patent Owner on issues not
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`solely involving Apple;
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`(e) Apple will not rely on expert testimony beyond that submitted by
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`Samsung. If Samsung’s participation is not terminated from the case prior to any
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`necessary depositions, Apple agrees to rely entirely on, and be bound by, the expert
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`declarations and depositions in the Samsung IPR. Unless and until the current
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`petitioner in IPR2022-00213 ceases to participate in the instituted Samsung IPR,
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`Apple will not assume an active role.2
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`Accordingly, due to Apple taking only an “understudy” role, Patent Owner
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`and Samsung will only need to respond to one principal set of papers, will not
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`require additional time to address additional arguments, and can thus proceed with
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`the existing trial schedule. These steps will minimize or eliminate any potential
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`complications or delay that could potentially result from joinder. See Sony, Paper
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`No. 11 at 6-7 (granting motion because “joinder would increase efficiency by
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`eliminating duplicative filings and discovery, and would reduce costs and burdens
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`on the parties as well as the Board” where second petitioner agreed to “understudy”
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`2 For clarity, should the Samsung IPR Petitioner’s participation in the Samsung
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`IPR terminate, Apple would take over primary responsibility for subsequent filings
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`and discovery.
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`role). Apple will also abide by any additional conditions the Board deems
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`appropriate for an “understudy” role.
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`5.
`Joinder Will Result in No Prejudice to Patent Owner
`As noted above, Apple’s joining of the Samsung IPR proceeding should not
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`result in any prejudice to Patent Owner. No additional grounds or arguments are
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`being introduced, no new substantive evidence or issues are being added, and no
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`additional discovery or briefing or oral argument should be necessary as a result of
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`Apple’s joinder. Thus, Patent Owner would not need to expend any additional
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`resources beyond those required in the current Samsung IPR.
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`III.
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`INSTITUTION IS APPROPRIATE UNDER GENERAL PLASTIC
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`General Plastic does not apply here because Apple has not previously
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`challenged the ’072 Patent and seeks to join the Samsung IPR in an understudy
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`role. See General Plastic Industrial Co., Ltd. v. Canon Kabushiki Kaisha,
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`IPR2016-01357, Paper 19 at 15-19 (PTAB Sept. 6, 2017); Apple Inc. v. Uniloc
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`2017 LLC, IPR2020-00224, Paper 10 at 4-5 (PTAB Apr. 6, 2020).
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`Factor 1: As to “whether the same petitioner previously filed a petition
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`directed to the same claims of the same patent,” Apple has not previously filed a
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`petition against the ’072 Patent.3 General Plastic at 16.
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`3 As previously noted, Apple is concurrently filing a second petition against the
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`Apple and Samsung are separate, unrelated petitioners, and are not similarly
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`situated for purposes of Factor 1. While the ’072 Patent was originally asserted
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`against Samsung in district court litigation, it was not accused of infringing the
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`patent based on sale of the same products as Apple. Nor has Apple or Samsung
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`provided any products or technology to the other leading to an allegation of
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`infringement of the ’072 Patent. While Apple and Samsung have jointly filed IPRs
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`against other patents asserted by the Patent Owner of the ’072 Patent in the parallel
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`litigation, the coordination and collaboration between the Samsung and Apple
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`started only after the Samsung IPR petition for the ’072 Patent was filed. Samsung
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`had prepared and filed the Samsung IPR petition for the ’072 Patent completely
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`independent of Apple. A relationship between Apple and Samsung did not exist
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`at the time of filing of the Samsung IPR petition, and Apple was not in a position
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`to collaborate with Samsung at that time. Under these circumstances, instead of
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`creating additional burden on Patent Owner by filing its own petition, Apple is
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`pursuing joinder with Samsung’s earlier effort. This factor weighs in favor of
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`institution and against discretionary denial.
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`Factors 2, 4 and 5: As to the timing examined in these factors, Apple did
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`not previously file a first petition prior to its current petition, and while Apple
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`’072 Patent. See supra n.1.
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`became aware of the prior art references in the Samsung IPR as of November 2021,
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`it made no serial attack on the ’072 Patent and has filed this petition for IPR within
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`the one-month time period under 37 C.F.R. § 42.122(b). These factors weigh in
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`favor of institution and against discretionary denial.
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`Factor 3: As Apple did not previously file a first petition, this factor weighs
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`in favor of institution and against discretionary denial.
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`Factors 6 and 7: As stated above, Apple seeks to join the Samsung IPR
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`and is not raising arguments beyond those raised by the Samsung IPR petition.
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`These factors thus weigh in favor of institution, as there should be no material
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`impact on the Board’s finite resources or its ability to issue a final determination
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`on the Samsung petition within one year.
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`IV.
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`INSTITUTION IS APPROPRIATE UNDER FINTIV
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`For the reasons explained in more detail below, and in Apple’s Petition, the
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`Fintiv factors weigh in favor of grant of this Motion for Joinder and institution of
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`the concurrently-filed Petition, and even more so because Apple merely seeks to
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`join an instituted IPR with a petition that relies on the same prior art references and
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`grounds set forth in the instituted IPR.
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`Factor 1. The first Fintiv factor is neutral. No motion to stay the parallel
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`litigation has been filed, and the district court has not otherwise ruled on any stay
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`motion. As the Board correctly recognized in the Samsung IPR, Factor 1 is neutral
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`because no motion to stay has been filed yet. IPR2022-00213, Paper 10 at 12
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`(finding that “this factor does not weigh for or against exercising our discretion to
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`deny institution”).
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`Factor 2. In the Samsung IPR, the Board found that this factor weighs “in
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`favor of exercising our discretion to deny” institution. Id. at 13. Apple submits that
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`this factor actually supports institution of Apple’s Petition and joinder to the
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`Samsung IPR. In the parallel litigation, the district court has set an initial trial date
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`of July 26, 2023, which is over a month after a Final Written Decision would be due
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`(June 8, 2023) in the Samsung IPR. Moreover, the scheduled trial date “is not by
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`itself a good indicator of whether the district court trial will occur before the statutory
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`deadline for a final written decision.” June 21, 2022, Memorandum from the
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`Director of the USPTO at 8. Indeed, the median time-to-trial from filing for civil
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`actions in the Western District of Texas is 27.2 months. See EX1021 at 37. Under
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`this timeline, the district court trial in the parallel litigation is likely to take place on
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`or around December 2023, which is well after the due date for the Final Written
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`Decision in the Samsung IPR. Because this IPR will have completed before the
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`district court trial, Factor 2 weighs in favor of institution.
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`Factor 3. The Board’s institution decision credited Samsung’s diligence in
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`filing the Samsung IPR immediately following receipt of Patent Owner’s
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`preliminary infringement contentions in the parallel district court litigation. See
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`IPR2022-00213, Paper 10 at 14. Apple here has also timely filed its Petition and
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`Motion for Joinder within the one-month deadline after institution of the Samsung
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`IPR. See supra § II.B. Moreover, Apple and the Patent Owner have expended few
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`resources in the litigation. Markman hearing has not taken place, fact discovery has
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`not begun, and no experts have prepared reports. As such, this factor weighs against
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`“exercising discretion to deny” institution. Sotera Wireless, Inc. v. Masimo Corp.,
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`IPR2020-01019, Paper 12 at 16-17 (P.T.A.B. Dec. 1, 2020).
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`In addition to the parties’ litigation, Patent Owner asserts the ’072 Patent
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`against Samsung, Google, and Amazon. See Apple’s Petition, Section X.B. The
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`circumstances of these proceedings also weigh against discretionary denial. Apple
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`is not a party to any of these proceedings. Stays remain possible for each of the cases,
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`although none have been filed yet. Regarding the Samsung case, it appears that
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`Patent Owner is no longer asserting the ’072 Patent against Samsung. The Google
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`case was filed on the same day as the case against Apple and shares the above
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`deadlines of the case against Apple. The Amazon case was filed later (November
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`29, 2021) and remains in its infancy, before claim construction briefings. Thus, for
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`each of the Samsung, Google, and Amazon cases, Apple is not a party, no claim
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`construction or other key substantive orders have issued, and the trial dates are
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`upwards of a year or more away.
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`Factor 4. While this Petition challenges claims 1-9 of the ’072 Patent, the
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`court has ordered that Patent Owner and Apple confer to “discuss significantly
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`narrowing the number of claims asserted,” meaning this Petition will likely
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`challenge a substantial number of claims not at issue in the litigation. EX1022 at
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`3. Further, Apple stipulates that, if this Petition is instituted, it will not pursue the
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`grounds identified in this Petition before the district court. Sand Revolution II, LLC
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`v. Cont’l Intermodal Grp.-Trucking LLC, IPR2019-01393, Paper 24 at 11-12
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`(P.T.A.B. June 16, 2020) (informative). In the Samsung IPR institution decision,
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`the Board recognized that Samsung’s “stipulation does minimize overlap with
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`regard to Zhang and Arndt specifically,” and therefore weighs “marginally against
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`exercising our discretion to deny institution.” IPR2022-00213, Paper 10 at 15.
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`Given that Apple’s Petition contains the same prior art and invalidity grounds as
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`the Samsung IPR, this factor weighs in favor of institution. Also, resolving the
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`invalidity questions here would mitigate concerns of duplicative efforts in the other
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`litigations involving the ’072 Patent, noted above, and in future cases.
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`Factor 5. Although Apple and Patent Owner are parties to co-pending
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`district court litigation, “[w]hether that fact weighs in favor of or against exercising
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`discretion to deny institution depends on which tribunal was likely to address the
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`challenged patent first.” Facebook, Inc. v. USC IP Partnership, L.P., IPR2021-
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`00033, Paper 13, 14-15 (PTAB Apr. 30, 2021). As noted above, the trial in the
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`14
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`parallel district court litigation is likely to be held after the deadline for a final
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`written decision in the Samsung IPR. See supra § IV, Factor 2. Accordingly,
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`Apple’s involvement as a Petitioner in IPR2022-00213 would impart estoppel on
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`Apple as a result of the Board’s final written decision and thereby reduce issues in
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`Apple’s co-pending litigation. As such, this factor weighs in favor of institution.
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`Factor 6. The Board held in the Samsung IPR that this factor was neutral.
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`See IPR2022-00213, Paper 10 at 17. Additional facts not present in the Samsung
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`IPR move this factor to favor institution of Apple’s petition and grant of its joinder.
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`Here, the Petition is merely a joinder to an instituted IPR and Apple will take an
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`inactive role (unless and until the Samsung IPR Petitoner ceases to participate).
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`Apple’s Petition includes the same prior art and grounds as the Samsung IPR, and
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`Samsung demonstrated that there is “a reasonable likelihood it would prevail in
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`establishing the unpatentability of all claims challenged in the petition.” Id. at 51.
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`As the Board determined in the Samsung IPR, the “interests of efficiency and
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`integrity of the system would [not] be best served” by denying institution of a
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`“potentially meritorious Petition.” Id. at 17.
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`V. CONCLUSION
`For the foregoing reasons, Apple respectfully requests that its Petition for
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`Inter partes review of the ’072 Patent be instituted and that Apple be joined to the
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`Samsung IPR proceeding IPR2022-00213.
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`Dated July 8, 2022
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`(Control No. IPR2022-01243)
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`Respectfully submitted,
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`/Jeremy J. Monaldo/
`W. Karl Renner, Reg. No. 41,265
`Jeremy Monaldo, Reg. No. 58,680
`Ayan Roy-Chowdhury, Reg. No. 72,483
`Fish & Richardson P.C.
`3200 RBC Plaza, 60 South Sixth Street
`Minneapolis, MN 55402
`T: 612-335-5070
`F: 612-288-9696
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`Attorneys for Petitioner
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`Case IPR2022-01243
`Attorney Docket No: 50095-0092IP1
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 CFR § 42.6(e), the undersigned certifies that on July 8, 2022,
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`a complete and entire copy of this Petitioner’s Motion for Joinder was provided by
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`Federal Express, to the Patent Owner, by serving the correspondence address of
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`record as follows:
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`NUTTER MCCLENNEN & FISH LLP
`SEAPORT WEST
`155 SEAPORT BOULEVARD
`BOSTON MA 02210-2604
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`17
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`/Crena Pacheco/
`Crena Pacheco
`Fish & Richardson P.C.
`60 South Sixth Street, Suite 3200
`Minneapolis, MN 55402
`(617) 956-5938
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