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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________________________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________________________________
`
`
`META PLATFORMS, INC.,
`Petitioner
`
`v.
`
`THALES VISIONIX, INC.,
`Patent Owner
`
`
`U.S. PATENT NO. 7,725,253
`
`Case No. IPR2022-01308
`
`
`PETITIONER’S REPLY TO PATENT OWNER’S OPPOSITION TO
`MOTION TO EXCLUDE EVIDENCE
`
`
`
`
`
`
`
`
`Petitioner’s Reply to Opposition to Motion to Exclude
`
`
`IPR2022-01308
`
`
`I.
`II.
`
`TABLE OF CONTENTS
`PARAGRAPHS 396-399, 409 OF EXHIBIT 2007 ..................................... 1
`EXHIBIT 2010 ............................................................................................... 1
`A.
`Petitioner Did Not Waive Its Objection ................................................ 1
`B.
`Patent Owner Delayed in Curing the Problem ...................................... 3
`C.
`Patent Owner Ignores the Board’s Ruling and Other Authority ........... 4
`III. EXHIBIT 2017 ............................................................................................... 5
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`
`i
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`Petitioner’s Reply to Opposition to Motion to Exclude
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`IPR2022-01308
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`TABLE OF AUTHORITIES
`
` Page(s)
`
`Cases
`Belden Inc. v. Berk-Tek LLC,
`805 F.3d 1064 (Fed. Cir. 2015) ............................................................................ 5
`Trane U.S. Inc. v. SEMCO, LLC,
`IPR2018-00514, Paper 36 (P.T.A.B. Apr. 17, 2019) ........................................... 5
`ZTE (USA), Inc. v. Cywee Grp. Ltd.,
`IPR2019-00143, Paper 87 (P.T.A.B. Feb. 17, 2021) .................................... 3, 4, 5
`Rules
`Fed. R. Evid. 402 ....................................................................................................... 5
`Fed. R. Evid. 611 ....................................................................................................... 5
`Fed. R. Evid. 702 ....................................................................................................... 1
`Other Authorities
`37 C.F.R.
`§ 42.10 ................................................................................................................... 3
`§ 42.53 ....................................................................................................... 1, 2, 3, 4
`§ 42.64 ................................................................................................................... 3
`
`
`
`
`
`
`ii
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`
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`Petitioner’s Reply to Opposition to Motion to Exclude
`
`
`IPR2022-01308
`
`
`
`
`Exhibit
`No.
`
`PETITIONER’S EXHIBIT LIST1
`
`Description
`
`Previously
`Filed
`
`1001 U.S. Patent No. 6,922,632
`
`1002
`
`File History of U.S. Patent No. 6,922,632
`
`1003 U.S. Patent No. 7,725,253
`
`1004
`
`File History of U.S. Patent No. 7,725,253
`
`1005 Declaration of Dr. Ulrich Neumann in Support of Inter
`Partes Review of U.S. Patent No. 6,922,632
`
`1006 Curriculum Vitae of Dr. Ulrich Neumann
`
`1007 Welch, G. et al., “High-Performance Wide-Area
`Optical Tracking” (2001)
`
`1008 Welch, G. et al., “SCAAT: Incremental Tracking with
`Incomplete Information” (1997)
`
`1009 Welch G. “SCAAT: Incremental Tracking with
`Incomplete Information” PhD Thesis, University of
`North Carolina (1996)
`
`1010 U.S. Patent No. 5,615,132
`
`1011 U.S. Patent No. 5,307,289
`
`1012 Gentex’s Amended Preliminary Infringement
`Contentions and corresponding Exhibits 4 and 5 (’632
`and ’253 infringement charts)
`
`1013 Azuma, R. “Predictive Tracking for Augmented
`Reality” PhD Thesis, University of North Carolina
`(1995)
`
`X
`
`X
`
`X
`
`X
`
`X
`
`X
`
`X
`
`X
`
`X
`
`X
`
`X
`
`X
`
`X
`
`
`1 All emphasis is added unless otherwise specified.
`
`iii
`
`
`
`Petitioner’s Reply to Opposition to Motion to Exclude
`
`
`Exhibit
`No.
`
`Description
`
`IPR2022-01308
`
`
`Previously
`Filed
`
`1014 You, S. and Neumann, U. “Orientation Tracking for
`Outdoor Augmented Reality Registration.” (1999)
`
`1015 Carlson, Neal A. and Berarducci, Michael P.
`“Federated Kalman Filter Simulation Results.”
`Navigation. Vol. 41, Issue 3 at 297-322. (Fall 1994)
`
`1016 Reitmayr, Gerhard and Schmalstieg. “An Open
`Software Architecture for Virtual Reality Interaction”
`VRST ’01 (November 2001)
`
`1017 Barfield, W. “Fundamentals of Wearable Computers
`and Augmented Reality” (2001)
`
`1018 Declaration of Rachel J. Watters regarding Welch, G.
`et al., “High-Performance Wide-Area Optical
`Tracking” (2001)
`
`1019 Declaration of Scott Delman regarding Welch, G. et al.,
`“SCAAT: Incremental Tracking with Incomplete
`Information” (1997)
`
`1020 Declaration of Dr. James L. Mullins regarding Welch
`G. “SCAAT: Incremental Tracking with Incomplete
`Information” PhD Thesis, University of North Carolina
`(1996)
`
`1021 Declaration of Scott Delman regarding Reitmayr,
`Gerhard and Schmalstieg. “An Open Software
`Architecture for Virtual Reality Interaction” VRST ’01
`(November 2001)
`
`1022 U.S. Patent No. 5,807,284
`
`1023 U.S. Patent No. 5,991,085
`
`X
`
`X
`
`X
`
`X
`
`X
`
`X
`
`X
`
`X
`
`X
`
`X
`
`iv
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`
`
`Petitioner’s Reply to Opposition to Motion to Exclude
`
`
`Exhibit
`No.
`
`Description
`
`IPR2022-01308
`
`
`Previously
`Filed
`
`1024 Chen, Steven C. and Lee, Kang. “A mixed-mode smart
`transducer interface for sensors and actuators”, Sound
`& Vibration, 32(4), 24-27 (April 1998)
`
`1025 Hoff, William and Vincent, Tyrone. “Analysis of Head
`Pose Accuracy in Augmented Reality”, IEEE
`Transactions on Visualization and Computer Graphics,
`Vol. 6, Issue 4, October – December 2000.
`
`1026
`
`Zetu, Dan et al., “Extended-Range Hybrid Tracker and
`Applications to Motion and Camera Tracking in
`Manufacturing Systems,” IEEE Transactions on
`Robotics and Automation, Vol. 16, Issue 3, June 2000
`
`1027 Declaration of Rachel J. Watters regarding Chen,
`Steven C. and Lee, Kang. “A mixed-mode smart
`transducer interface for sensors and actuators.” Sound
`& Vibration, 32(4), 24-27 (April 1998)
`
`1028 Declaration of Gordon MacPherson regarding Hoff,
`William and Vincent, Tyrone. “Analysis of Head Pose
`Accuracy in Augmented Reality”, IEEE Transactions
`on Visualization and Computer Graphics, Vol. 6, Issue
`4, October – December 2000.
`
`1029 Declaration of Gordon MacPherson regarding Zetu,
`Dan et al., “Extended-Range Hybrid Tracker and
`Applications to Motion and Camera Tracking in
`Manufacturing Systems,” IEEE Transactions on
`Robotics and Automation, Vol. 16, Issue 3, June 2000
`
`1030 U.S. Patent No. 5,592,401
`
`X
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`X
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`X
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`X
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`X
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`X
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`X
`
`v
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`
`
`Petitioner’s Reply to Opposition to Motion to Exclude
`
`
`Exhibit
`No.
`
`Description
`
`IPR2022-01308
`
`
`Previously
`Filed
`
`1031 Case Management and Pretrial Order, Dkt. 116, Gentex
`Corporation et al. v Meta Platforms, Inc. et al.
`(October 18, 2022)
`
`1032 Declaration of Akshay S. Deoras in Support of
`Unopposed Motion to Appear Pro Hac Vice on Behalf
`of Petitioner
`
`1033 Deposition Transcript of Yohan Baillot, dated
`September 13, 2023
`
`1034
`
`1035
`
`Excerpts from Random House Webster’s Unabridged
`Dictionary, 2nd Ed. (2001)
`
`Excerpts from The Computer Engineering Handbook
`(2001)
`
`1036 Compare Benefits of CPUs, GPUs, and FPGAs for
`Different oneAPI Compute Workloads
`
`1037
`
`1038
`
`1039
`
`1040
`
`Plaintiffs’ Disclosure of Asserted Claims and
`Infringement Contentions Pursuant to Patent L.R. 3-1,
`Gentex Corp. v. Meta Platforms, Inc., No. 22-cv-3892-
`YGR (N.D. Cal. Oct. 21, 2022)
`
`Supplemental Declaration of Dr. Ulrich Neumann in
`Support of Inter Partes Review of U.S. Patent Nos.
`6,922,632 and 7,725,253
`
`Email correspondence from Patent Trial & Appeal
`Board to parties’ counsel, dated May 31, 2023
`
`Email correspondence from Patent Owner’s counsel to
`Petitioner’s counsel, dated October 1, 2023
`
`X
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`X
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`X
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`X
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`X
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`X
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`X
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`X
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`X
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`X
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`
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`
`
`vi
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`Petitioner’s Reply to Opposition to Motion to Exclude
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`IPR2022-01308
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`
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`Exhibit
`No.
`2001
`
`PATENT OWNER’S EXHIBIT LIST
`
`Description
`Complaint, Gentex Corp. v. Meta Platforms, Inc., No.
`6:21- cv-00755-ADA (W.D. Tex. July 22, 2021), ECF
`No. 1.
`
`Filed
`X
`
`2002
`
`2003
`
`2004
`
`2005
`
`2006
`
`2007
`
`2008
`
`2009
`
`Joint Order Regarding Claim Construction and
`Discovery, Gentex Corp. v. Meta Platforms, Inc., No.
`5:22-cv-03892- YGR (N.D. Cal. Nov. 9, 2022), ECF
`No. 118
`
`Gentex Corp. v. Meta Platforms, Inc., No. 5:22-cv-
`03892- YGR (N.D. Cal.), Letter from Laura Ashley
`Harris to Andrew Borrasso (Feb. 3, 2023)
`
`Gentex Corp. v. Meta Platforms, Inc., No. 5:22-cv-
`03892- YGR (N.D. Cal.), Excerpts of Invalidity
`Contentions of Meta Platforms, Inc. (Dec. 5, 2022)
`
`Declaration of Adam D. Harber in Support of
`Unopposed Motion for Pro Hac Vice Admission
`Pursuant to 37 C.F.R. § 42.10(c)
`
`Declaration of Melissa B. Collins in Support of
`Unopposed Motion for Pro Hac Vice Admission
`Pursuant to 37 C.F.R. § 42.10(c)
`
`Declaration of Yohan Baillot in Support of Patent
`Owner’s Responses to Petitions for Inter Partes
`Review of U.S. Patent Nos. 6,922,632 and 7,725,253
`(June 14, 2023)
`
`Curriculum Vitae of Yohan Baillot
`
`Transcript of the Deposition of Dr. Ulrich Neumann
`(June 1, 2023)
`
`vii
`
`X
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`X
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`X
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`X
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`X
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`X
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`X
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`X
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`
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`Petitioner’s Reply to Opposition to Motion to Exclude
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`IPR2022-01308
`
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`Exhibit
`No.
`2010
`
`Description
`Excerpt of Transcript of the Deposition of Dr. Ulrich
`Neumann (May 23, 2023)
`
`Filed
`X
`
`2011
`
`2012
`
`2013
`
`2014
`
`2015
`
`2016
`
`2017
`
`2018
`
`Couple, American Heritage Dictionary (4th ed. 2000)
`
`Configure, Merriam-Webster’s Collegiate Dictionary
`(10th ed. 1999)
`
`Configure, American Heritage Dictionary (4th ed.
`2000)
`
`Configure, Random House Webster’s Unabridged
`Dictionary (2d ed. 2001)
`
`Enumerate, Merriam-Webster’s Collegiate Dictionary
`(10th ed. 1999)
`
`Enumerate, American Heritage Dictionary (4th ed.
`2000)
`
`IEEE 1451.4-2004, IEEE SA (last visited June 8,
`2023)
`
`Inertial Motion-Tracking Technology for Virtual 3-D,
`NASA Spinoff (originally published in 2005)
`
`2019
`[not filed]
`
`Declaration of Yohan Baillot in Support of Patent
`Owner’s Responses to Petitions for Inter Partes
`Review of U.S. Patent Nos. 6,922,632 and 7,725,253
`with attachment (July 7, 2023)
`
`2020
`
`2021
`
`Declaration of Glen Parker (June 29, 2023)
`
`Couple, Merriam-Webster’s Collegiate Dictionary
`(10th ed. 1999)
`
`X
`
`X
`
`X
`
`X
`
`X
`
`X
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`X
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`X
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`
`
`X
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`X
`
`viii
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`
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`Petitioner’s Reply to Opposition to Motion to Exclude
`
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`IPR2022-01308
`
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`Exhibit
`No.
`2022
`
`Description
`Couple, Random House Webster’s Unabridged
`Dictionary (2d ed. 2001)
`
`2023
`[not filed]
`
`Enumerate, Random House Webster’s Unabridged
`Dictionary (2d ed. 2001)
`
`2024
`[not filed]
`
`Enumerate, Merriam-Webster’s Collegiate Dictionary
`(10th ed. 1999)
`
`2025
`
`2026
`
`Transcript of the Deposition of Dr. Ulrich Neumann
`(October 20, 2023)
`
`October 24, 2023 Deposition Transcript of Glen
`Parker, Jr.
`
`2027 May 3, 2023 Email Correspondence
`
`2028 May 22, 2023 Email Correspondence
`
`Filed
`X
`
`
`
`
`
`X
`
`X
`
`X
`
`X
`
`
`
`
`
`ix
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`
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`Petitioner’s Reply to Opposition to Motion to Exclude
`
`
`IPR2022-01308
`
`
`I.
`
`PARAGRAPHS 396-399, 409 OF EXHIBIT 2007
`Patent Owner (“PO”) agrees that certain of Mr. Baillot’s opinions are
`
`irrelevant, so they should be excluded as irrelevant. See Paper 41, 1, n.1. As to the
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`allegedly relevant remaining portions, PO argues that Mr. Baillot “did not have
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`‘enough data’ to answer” to answer” the questions posed to him, but that does not
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`excuse Mr. Baillot’s black-box analysis; it was his burden to reliably apply reliable
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`principles and methods to the facts of the case. Id., 5-7; FRE 702(b-d). These
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`paragraphs of Exhibit 2007 should therefore be excluded.
`
`II. EXHIBIT 2010
`The Board should exclude Exhibit 2010, or in the alternative, the specific
`
`excerpts relied upon by PO, as identified in Paper 38, 6 (Section II.B).
`
`A.
`Petitioner Did Not Waive Its Objection
`First, there was no waiver. Petitioner timely objected on the record pursuant
`
`to the governing regulations for taking testimony. 37 C.F.R. § 42.53(f)(8) (“Any
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`objection to the content, form, or manner of taking the deposition, including the
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`qualifications of the officer, is waived unless made on the record during the
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`deposition and preserved in a timely filed motion to exclude.”). Petitioner complied
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`with these requirements. See Ex-2010, 7:24-8:8; Papers 30, 38.
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`Second, Patent Owner’s waiver argument, which is premised on what it claims
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`Petitioner “should have” done, is premised on the wrong regulation. PO argues
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`Petitioner failed to object to “a defect in the notice” under 37 C.F.R. § 42.53(d)(6).
`1
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`
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`Petitioner’s Reply to Opposition to Motion to Exclude
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`
`IPR2022-01308
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`Paper 41, 9. This provision is related to § 42.53(d)(5), which governs the scope and
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`content of a notice of deposition (i.e., must include the time and place of deposition).
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`§ 42.53(d)(5) does not require a notice of deposition to identify who would be asking
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`questions at the deposition. Thus, there was no “defect in the notice” to which
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`Petitioner could have moved to quash under § 42.53(d)(6); the scope and content of
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`the notice were that which the parties already agreed. 37 C.F.R. §§ 42.53(d)(1),
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`(d)(5).2 An objection to who asks questions is embodied by the “manner of taking
`
`the deposition” in § 42.53(f)(8) discussed above.
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`Third, even if the notice contained a “defect” for which Petitioner could have
`
`moved to quash, PO cannot argue Petitioner waived when PO itself was too late. PO
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`admits it did not file its notice of deposition on or before May 9 for a deposition on
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`May 23 pursuant to 37 C.F.R. § 42.53(d)(4) (“party seeking the deposition must file
`
`a notice of the deposition at least ten business days before a deposition”). PO offers
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`no justification (because there is none) for why it did not timely file its notice,
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`especially when its counsel accepted the deposition date on May 3, thirteen business
`
`days before the deposition. Ex-2027, 2 (“May 23 date[] work[s]”).
`
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`2 PO’s arguments that Petitioner should have known that counsel for non-party
`
`Gentex “would be questioning Dr. Neumann” because they participated in email
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`correspondence (Paper 41, 9-10) is irrelevant for this same reason.
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`2
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`Petitioner’s Reply to Opposition to Motion to Exclude
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`IPR2022-01308
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`Last, PO’s reliance on ZTE is misplaced. ZTE addressed the timeliness of
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`objections to admissibility of deposition evidence (i.e., exhibits relied upon in the
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`deposition) under § 42.64(a)—not objections to a defect in the notice under
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`§ 42.53(d)(6). See ZTE (USA), Inc. v. Cywee Grp. Ltd., No. IPR2019-00143, Paper
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`87, 103; Paper 41, 9-10; 37 C.F.R. § 42.64(a) (“An objection to the admissibility of
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`deposition evidence must be made during the deposition.”).3
`
`B.
`Patent Owner Delayed in Curing the Problem
`PO and non-party Gentex argue that Petitioner “deprived” them of the
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`opportunity to cure the problem, and allege that “as soon as [PO] was on notice of
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`the objection, it acted quickly to permit Williams & Connolly to represent it before
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`the Board.” Paper 41, 11. This is false. PO’s COO, Mr. Glen Parker, who executed
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`all of PO’s Powers of Attorney, was informed of Petitioner’s objection by PO’s
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`counsel “either that same day or shortly thereafter within days.” Ex-2026, 38:17-
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`39:2. Yet PO’s updated Power of Attorney was not executed and filed until eight
`
`days later, even though Mr. Parker admitted that he could have provided an updated
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`Power of Attorney “within two or three hours” of a request by counsel to do so. Ex-
`
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`3 PO’s distinction between § 42.64(b) versus §42.64(a) (Paper 41, 12-13) is
`
`irrelevant. §42.64(a) does not apply because Exhibit 2010 is not “deposition
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`evidence,” but rather the transcript of the deposition itself.
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`3
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`Petitioner’s Reply to Opposition to Motion to Exclude
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`IPR2022-01308
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`2026, 50:17-18, 57:11-13 (“I would have prioritized it because this is important”).
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`Indeed, Mr. Parker executed PO’s updated Power of Attorney the same day as the
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`Board’s May 31 ruling. Id., 50:16-18; Ex-2020, ¶ 6; Paper 27; Ex-1039. PO’s
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`failure to file the updated Power of Attorney the day of the deposition to cure the
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`problem is thus entirely PO’s own fault. See Ex-2026, 50:23-51:5.
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`PO’s argument that an earlier objection by Petitioner would have changed
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`PO’s approach is directly contradicted by Mr. Parker, who testified that he did not
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`provide an updated Power of Attorney sooner because “counsel did not think that it
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`was necessary [in order for non-party Gentex’s attorneys to ask questions] and so
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`we did not until the [Board’s] ruling.” Ex-2026, 52:20-25. Thus, PO expressly
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`admits that even if Petitioner had raised its objection before the deposition, PO still
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`would have done nothing unless and until Petitioner sought relief from the Board.
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`The issue here is not that Petitioner did not make its objection known in time.
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`See Section II.A. The issue is instead that Petitioner timely objected under
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`§ 42.53(f)(8) to non-party Gentex’s attempted questioning, and PO waited over a
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`week to execute an updated Power of Attorney. PO’s failure to promptly cure the
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`problem raised by Petitioner’s objection, along with any purported prejudice, is
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`therefore wholly of PO’s own making.
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`C.
`Patent Owner Ignores the Board’s Ruling and Other Authority
`PO mischaracterizes the Board’s May 31 ruling as applicable only to “future
`
`4
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`Petitioner’s Reply to Opposition to Motion to Exclude
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`IPR2022-01308
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`depositions” in other IPR proceedings involving the same parties. Paper 41, 14.
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`This is incorrect. Petitioner’s requested relief to the Board sought to preclude
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`submission of “cross-examination conducted [past tense] by counsel for Gentex,” in
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`addition to questioning by counsel for Gentex in upcoming depositions. Ex-1039, 2
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`(subject line identifying this proceeding, IPR2022-01294, in addition to other IPRs).
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`The Board was not silent as to Petitioner’s remedy; it concisely clarified that only
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`counsel for which PO filed a power of attorney may question Petitioner’s expert.
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`Id., 1. It is PO that seeks to “rewrite history” because the Board’s ruling emphasizes
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`PO’s noncompliant conduct and supports exclusion of Exhibit 2010.
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`PO further claims Petitioner provided no authority to justify excluding
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`Dr. Neumann’s improperly elicited testimony. Paper 41, 13. Not so. See Paper 30,
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`2-4; Paper 38, 6, 9-11, 13; Belden Inc. v. Berk-Tek LLC, 805 F.3d 1064, 1081 (Fed.
`
`Cir. 2015) (Board “has broad discretion to regulate the presentation of evidence”
`
`under FRE 611(a)); Trane U.S. Inc. v. SEMCO, LLC, IPR2018-00514, Paper 36, 8
`
`(“[W]e cannot overlook a party’s blatant disregard of our rules and practice….”).
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`III. EXHIBIT 2017
`PO failed to even address Exhibit 2017. Compare Paper 41 with Paper 38.
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`This exhibit is undisputedly irrelevant, and therefore inadmissible under FRE 402.
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`5
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`Petitioner’s Reply to Opposition to Motion to Exclude
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`IPR2022-01308
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`
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`Date: December 1, 2023
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`
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`Respectfully submitted,
`
`/W. Todd Baker /
`W. Todd Baker (No. 45,265)
`todd.baker@kirkland.com
`KIRKLAND & ELLIS LLP
`1301 Pennsylvania Ave., N.W.
`Washington, D.C. 20004
`Telephone: (202) 389-5000
`Facsimile: (202) 389-5200
`
`Ellisen Shelton Turner (No. 54,503)
`ellisen.turner@kirkland.com
`Joshua Popik Glucoft (No. 67,696)
`josh.glucoft@kirkland.com
`KIRKLAND & ELLIS LLP
`2049 Century Park East,
`Los Angeles, CA 90067
`Telephone: (310) 552-4200
`Facsimile: (310) 552-5900
`
`Akshay S. Deoras (pro hac vice)
`akshay.deoras@kirkland.com
`KIRKLAND & ELLIS LLP
`555 California Street
`San Francisco, CA 94104
`Telephone: (415) 439-1400
`Facsimile: (415) 439-1500
`
`Yimeng Dou (No. 69,770)
`yimeng.dou@kirkland.com
`KIRKLAND & ELLIS LLP
`555 South Flower Street, Suite 3700
`Los Angeles, CA 90071
`Telephone: (213) 680-8400
`Facsimile: (213) 680-8500
`
`Attorneys for Petitioner
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`6
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`Petitioner’s Reply to Opposition to Motion to Exclude
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`IPR2022-01308
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`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a copy of the foregoing document was
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`served on December 1, 2023 via electronic mail directed to counsel of record for the
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`Patent Owner at the following:
`
`Thales-Meta-IPRs@addyhart.com
`
`Gentex-IPR@wc.com
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`/W. Todd Baker/
`W. Todd Baker (No. 45,265)
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