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 IPR2022-01244
`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 IPR2022-01244
`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 IPR2022-01244
`Attorney Docket No: 50095-0092IP2
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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 IPR2022-00630
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`(“Google IPR”), which was filed on March 1, 2022. Google LLC v. Jawbone
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`Innovations, LLC, IPR2022-00630. Apple’s Petition is substantively the same as the
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`Google IPR petition. It challenges the same claims, on the same grounds, relies on
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`the same prior art as the Google IPR, and relies on the same expert declaration.
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`Therefore, joinder would create no additional burden for the Board, the Google IPR
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`Petitioner (“Google”), or Patent Owner if joined. Joinder would therefore lead to an
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`efficient 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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`different grounds and relying on different references. See IPR2022-01243.
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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 Google ceases to participate in the proceeding.
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`Google will maintain the lead role in the proceeding so long as it remains in the
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`proceeding. These limitations will avoid lengthy and duplicative briefing. Apple
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`also will not seek additional depositions or deposition time. Joinder will not impact
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`the trial schedule because the proceeding based on the Google IPR is in its early
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`stages.
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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 Google IPR
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`for all interested parties.
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`Joinder will not unduly prejudice any party. Indeed, Google does not oppose
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`this motion. Also, because joinder will not add any new substantive issues, delay
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`the schedule, burden deponents, or needlessly increase filings, any additional costs
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`on Patent Owner will be minimal. On the other hand, denial of joinder would
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`prejudice Apple. Apple’s interests may not be adequately protected in the Google
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`IPR, particularly if Google settles with Patent Owner and ceases to participate.
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`Apple should be allowed to join in a proceeding affecting a patent asserted against
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`it.
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`Given the similarities of the proceedings, the lack of undue prejudice to Patent
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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 Google IPR in the event that Google’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., IPR2013-00385, 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 Google IPR was filed on March 1, 2022, and the Patent Owner Preliminary
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`Response was filed on June 16, 2022. IPR2022-00630, Paper 3 (March 1, 2022),
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`Paper 6 (June 16, 2022). The Board is yet to issue its decision on institution, which
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`is not due until September 16, 2022. Id. at Paper 5. Apple’s current motion is
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`timely as it is being filed within the permissible time frame.
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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 Google
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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 Google IPR. Moreover, the briefing and discovery
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`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 Google 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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`Google’s participation is terminated prior to completion. Thus, joining Apple to
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`the Google 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 Google
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`IPR can be determined in a single proceeding. Joinder also is appropriate because
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`Apple’s Petition challenges the validity of the same claims of the ’072 Patent on
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`Case IPR2022-01244
`Attorney Docket No: 50095-0092IP2
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`identical grounds to those in the Google IPR. There are no substantive differences
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`between Apple’s Petition and the Google IPR Petition, IPR2022-00630, Paper 3
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`(March 1, 2022). Apple also relies on the same substantive evidence in its Petition
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`as is relied on in the Google IPR. A consolidated proceeding, including Apple and
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`Google, will therefore be more efficient and less wasteful, as only a single trial on
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`these common grounds would be required. See, e.g., Oracle America Inc. v.
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`Realtime Data LLC, IPR2016-01672, Paper 13 at 7 (PTAB Mar. 7, 2017) (noting
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`that “joining Oracle’s identical challenges to those in the 1002 IPR will lead to
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`greater efficiency while reducing the resources necessary from both Realtime and
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`the Board”). The Board “routinely grants motions for joinder where the party
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`seeking joinder introduces identical arguments and the same grounds raised in the
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`existing proceeding.” Google Elecs. Co., Ltd. v. Raytheon Co., IPR2016-00962,
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`Paper 12 at 9 (PTAB Aug. 24, 2016) (internal quotations and citations omitted).
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`Joining Apple as a party to the Google 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 Google. 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 Google’s Petition
`Apple’s Petition challenges the validity of the ’072 Patent on identical
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`grounds to those in the Google IPR. See IPR2022-00630, Paper 3 (March 1, 2022).
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`Apple’s substantive evidence―including its supporting expert declaration and
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`substantive exhibits ―are identical to those presented in the Google IPR. Further,
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`unity of exhibits and exhibit numbering with the Google IPR has been maintained.
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`Accordingly, no new grounds are being introduced. See Sony Corp. v. Memory
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`Integrity, LLC, IPR2015-01353, Paper No. 11 at 5-6 (PTAB Oct. 5, 2015) (granting
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`motion for joinder where petitioners relied “on the same prior art, same arguments,
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`and same evidence, including the same expert and a substantively identical
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`declaration”).
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`Therefore, consolidation of this proceeding with Google’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 Google IPR
`Given that the Board is yet to rule on institution of review of the Google
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`IPR, joinder of Apple would not affect the schedule in any forthcoming trial.
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`Apple’s participation should result in no changes to the schedule.
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`Should the Google IPR petition get instituted, Apple agrees to adhere to all
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`Case IPR2022-01244
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`applicable deadlines set forth in the Google IPR Scheduling Order. The Patent
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`Owner’s Response will not be affected because the issues in Apple’s Petition are
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`identical to those in the Google IPR petition. Patent Owner will thus not be required
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`to provide any additional analysis or 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
`Google Petitioner Remains
`To further prevent joinder from imposing any burden on Google, 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 Google remains a party to the Google
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`IPR, to take an understudy role, which will simplify briefing and discovery. In this
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`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 Google, 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 Google, 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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`Google. If Google’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 Google IPR. Unless and until the current
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`petitioner in IPR2022-00630 ceases to participate in the Google IPR, Apple will
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`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 Google will only need to respond to one principal set of papers, will not require
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`additional time to address additional arguments, and can thus proceed with the
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`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 Google’s participation in the Google IPR terminate, Apple
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`would take over primary responsibility for subsequent filings and discovery.
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`role). Apple will also abide by any additional conditions the Board deems
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`Case IPR2022-01244
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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 Google 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 Google 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 Google IPR in an understudy role.
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`See General Plastic Industrial Co., Ltd. v. Canon Kabushiki Kaisha, IPR2016-
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`01357, Paper 19 at 15-19 (PTAB Sept. 6, 2017); Apple Inc. v. Uniloc 2017 LLC,
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`IPR2020-00224, Paper 10 at 4-5 (PTAB Apr. 6, 2020).
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`Factor 1: Under General Plastic, factor 1 considers “whether the same
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`petitioner previously filed a petition directed to the same claims of the same
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`patent.” General Plastic at 16. Here, Apple has not previously filed a petition
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`against the ’072 Patent.3
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`Case IPR2022-01244
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`Apple and Google are separate, unrelated petitioners, and are not similarly
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`situated for purposes of Factor 1. While the ’072 Patent has been asserted against
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`Google in district court litigation, it has not been accused of infringing the patent
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`based on sale of the same products as Apple. Nor has Apple or Google provided
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`any products or technology to the other leading to an allegation of infringement of
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`the ’072 Patent. This factor weighs in favor of institution and against discretionary
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`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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`became aware of a prior art reference in the Google IPR prior to filing of the
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`Google IPR petition, it made no serial attack on the ’072 Patent. Instead, Apple
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`has filed this petition for IPR along with the joinder motion within the time period
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`set forth in 37 C.F.R. § 42.122(b). These factors weigh in favor of institution and
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`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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`3 As previously noted, Apple is concurrently filing a second petition against the
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`’072 Patent. See supra n.1.
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`Factors 6 and 7: As stated above, Apple seeks to join the Google IPR and
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`is not raising arguments beyond those raised by the Google IPR petition. These
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`factors thus weigh in favor of institution, as there should be no material impact on
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`the Board’s finite resources or its ability to issue a final determination on the
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`Google 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 already-filed IPR with a petition that relies on the same prior art references
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`and grounds set forth in the IPR as filed.
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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. See Sotera Wireless, Inc. v. Masimo Corp., IPR2020-01019, Paper 12 at
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`11-21 (P.T.A.B. Dec. 1, 2020) (precedential) (citing Apple Inc. v. Fintiv, Inc.,
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`IPR2020-00019, Paper 11 (P.T.A.B. Mar. 20, 2020) (precedential)).
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`Factor 2. This factor supports institution of Apple’s Petition and joinder to
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`the Google IPR. In the parallel litigation, the district court has set an initial trial date
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`of July 26, 2023. Although this date is a month before a Final Written Decision
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`would be due (September 16, 2023) in the Google IPR, such “scheduled trial dates
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`are unreliable and often change” and “is not by itself a good indicator of whether the
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`district court trial will occur before the statutory deadline for a final written
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`decision.” June 21, 2022, Memorandum from the Director of the USPTO at 8.
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`Indeed, the median time-to-trial from filing for civil actions in the Western District
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`of Texas is 27.2 months. Ex. 1016 at 37. Under this timeline, the district court trial
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`in the parallel litigation is likely to take place on or around December 2023, which
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`is well after the due date for the Final Written Decision in the Google IPR. Because
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`this IPR will have completed before the district court trial, Factor 2 weighs in favor
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`of institution.
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`Factor 3. Apple here has timely filed its Petition and Motion for Joinder. See
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`supra Section II.B. The parties have expended few resources in the litigation. As of
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`the filing of Apple’s Petition, Markman hearing has not taken place, fact discovery
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`has not begun, and no experts have prepared reports. Apple’s diligence averts
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`parallel, duplicative proceedings, and any unfair costs to Patent Owner. Sotera
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`Wireless, Inc. v. Masimo Corp., IPR2020-01019, Paper 12 at 16-17 (P.T.A.B. Dec.
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`1, 2020).
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`In addition to the parties’ litigation, Patent Owner has asserted the ’072 Patent
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`against Samsung, Google, and Amazon. See Apple’s Petition, Section VIII.B. The
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`circumstances of these proceedings weigh also 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. And 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. As such, this factor weighs strongly against
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`discretionary denial.
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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). Also, Patent Owner has asserted the ’072
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`Patent in other litigations. See Apple’s Petition, Section VIII.B. Resolving the
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`invalidity questions here would mitigate concerns of duplicative efforts in those
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`cases, 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 with respect to
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`Fintiv Factor 2, the trial in the parallel district court litigation is likely to be held
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`after the deadline for a final written decision in the Google IPR. See supra Section
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`IV, Factor 2. As such, this factor weighs in favor of institution.
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`Factor 6. The challenged claims are unpatentable over prior art not
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`considered during prosecution. See Ex. 1001, Cover. There is a significant public
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`interest against “leaving bad patents enforceable.” Thryv, Inc v. Click-To- Call
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`Techs., LP, 140 S. Ct. 1367, 1374 (2020). Apple’s grounds establish that each and
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`every element was known in the art, and that claims 1-9 are unpatentable. The
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`strength of the Petition weighs against discretionary denial. Sand Revolution II,
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`Paper 24 at 13. The Petition is also merely a joinder to an already-filed IPR
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`petition, relying on the same prior art and grounds as the Google IPR, and Apple
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`will take an inactive role (unless and until the Google ceases to participate in its
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`petition).
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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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`Google IPR proceeding IPR2022-00630.
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`Dated July 8, 2022
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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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`(Control No. IPR2022-01244)
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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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`/Crena Pacheco/
`Crena Pacheco
`Fish & Richardson P.C.
`60 South Sixth Street, Suite 3200
`Minneapolis, MN 55402
`(617) 956-5938
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