IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
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`
`Xiaodong Li, et al.
`In re Patent of:
`10,965,512 Attorney Docket No.: 18768-0206IP1
`U.S. Patent No.:
`March 30, 2021
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`Issue Date:
`Appl. Serial No.: 17/012,813
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`Filing Date:
`September 4, 2020
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`Title:
`METHOD AND APPARATUS USING CELL-SPECIFIC AND
`COMMON PILOT SUBCARRIERS IN MULTI-CARRIER,
`MULTI CELL WIRELESS COMMUNICATION NETWORKS
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`
`Mail Stop Patent Board
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`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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`Xiaodong Li, et al.
`In re Patent of:
`10,965,512 Attorney Docket No.: 18768-0206IP1
`U.S. Patent No.:
`March 30, 2021
`
`Issue Date:
`Appl. Serial No.: 17/012,813
`
`Filing Date:
`September 4, 2020
`
`Title:
`METHOD AND APPARATUS USING CELL-SPECIFIC AND
`COMMON PILOT SUBCARRIERS IN MULTI-CARRIER,
`MULTI CELL WIRELESS COMMUNICATION NETWORKS
`
`
`
`Mail Stop Patent Board
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`
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`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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`I.
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`Case IPR2023-00961
`Attorney Docket No: 18768-0206IP1
`STATEMENT OF PRECISE RELIEF REQUESTED
`General Motors LLC, Nissan North America, Inc., Tesla, Inc., and American
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`Honda Motor Co., Inc. (collectively “Petitioner” or “Petitioners”) respectfully
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`submit this Motion for Joinder, concurrently with a Petition for inter partes review
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`of U.S. Patent No. 10,965,512 (“the ’512 Patent”).
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`Pursuant to 35 U.S.C. § 315(c) and 37 C.F.R. §§ 42.22 and 42.122(b),
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`Petitioners move for joinder with the IPR recently instituted on May 2, 2023 in
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`IPR2022-01539 (“VW IPR”). Volkswagen Group of America Inc. v. Neo Wireless
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`LLC, IPR2022-01539, Paper 7 (PTAB May 2, 2023). Petitioners’ concurrently-filed
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`Petition is substantively the same as the VW IPR petition. It challenges the same
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`claims, on the same grounds, and relies on the same prior art as instituted in the VW
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`IPR and therefore would create no additional burden for the Board, the VW IPR
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`Petitioner, or Patent Owner if joined. Joinder would therefore lead to an efficient
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`resolution of the validity of the ’512 patent.
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`Petitioners are currently defendants in a multidistrict court litigation in the
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`Eastern District of Michigan, In re Neo Wireless, LLC Patent Litig., 2:22-md-3034-
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`TGB (E.D. MI). In this proceeding, Petitioners have been accused of infringing the
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`’512 patent. Petitioners have not previously filed a petition for IPR challenging the
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`validity of the ’512 patent.
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`Petitioners stipulate that if joinder is granted, they will act as an “understudy”
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`Case IPR2023-00961
`Attorney Docket No: 18768-0206IP1
`and will not assume an active role unless the VW IPR Petitioner ceases to participate
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`in the proceeding. The VW IPR Petitioner will maintain the lead role in the
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`proceeding so long as it remains in the proceeding. These limitations will avoid
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`lengthy and duplicative briefing. Petitioners also will not seek additional depositions
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`or deposition time. Joinder will not impact the trial schedule because the proceeding
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`based on the VW IPR is in its early stages having just instituted on May 2, 2023.
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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 VW IPR for
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`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 Petitioners. Petitioners’ interests may not be
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`adequately protected in the VW IPR, particularly if the VW IPR Petitioner settles
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`with Patent Owner and ceases to participate. Petitioners should be allowed to join
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`in a proceeding affecting a patent asserted against them.
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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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`Peitioners’ cooperative participation in the VW IPR in the event that the VW IPR
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`Petitioner’s participation terminates, the Board should institute IPR and grant
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`Case IPR2023-00961
`Attorney Docket No: 18768-0206IP1
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`Petitioners’ instant Motion 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, up to one
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`month after the institution date of the proceeding to which joinder is requested. 37
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`C.F.R. § 42.122(b); Taiwan Semiconductor Mfg. Co., Ltd. v. Zond LLC, IPR2014-
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`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.
`Petitioner’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 VW IPR was instituted on May 2, 2023. IPR2022-01539, Paper 7 (PTAB
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`May 2, 2023). Petitioners’ current motion is timely as it is being filed within one
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`Attorney Docket No: 18768-0206IP1
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`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 Petitioners’ Motion for
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`Joinder. Petitioners’ Petition is substantively identical to the petition in the VW
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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 VW 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 Petitioners Is Appropriate Because It Will
`Promote an Efficient Determination of the Validity of the
`’512 Patent Without Prejudice to Any Party
`Petitioners seek to join the VW IPR in order to ensure that accused infringers
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`with an active interest in the proceeding remains a party to this IPR if the VW IPR
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`Petitioner’s participation is terminated prior to completion. Thus, joining
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`Petitioners to the VW IPR is the most practical way to secure the just, speedy, and
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`inexpensive resolution of the challenge to the ‘512 patent. See 37 C.F.R. § 42.1(b).
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`If Petitioners are joined as parties, the validity of the grounds raised in the
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`VW IPR can be determined in a single proceeding. Joinder is also appropriate
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`because Petitioners’ petition challenges the validity of the same claims of the ’512
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`patent on identical grounds to those in the VW IPR. There are no substantive
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`differences between Petitioners’ and the VW IPR Petitioner’s Petition, IPR2022-
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`01539, Paper 1 (September 15 2022). Petitioners also rely on substantially the
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`Attorney Docket No: 18768-0206IP1
`same supporting evidence in its Petition as is relied on in the VW IPR.1 A
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`consolidated proceeding, including Petitioners and the VW IPR Petitioner, will
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`therefore be more efficient and less wasteful, as only a single trial on these
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`common grounds would be required. See, e.g., Oracle America Inc. v. Realtime
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`Data LLC, IPR2016-01672, Paper 13 at 7 (PTAB Mar. 7, 2017) (noting that
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`“joining Oracle’s identical challenges to those in the 1002 IPR will lead to greater
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`efficiency while reducing the resources necessary from both Realtime and the
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`Board”). The Board “routinely grants motions for joinder where the party seeking
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`joinder introduces identical arguments and the same grounds raised in the existing
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`proceeding.” GM Elecs. Co., Ltd. v. Raytheon Co., IPR2016- 00962, Paper 12 at
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`9 (PTAB Aug. 24, 2016) (internal quotations and citations omitted).
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`Joining Petitioners as a party to the VW IPR would promote the public
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`1 The supporting expert declaration of Dr. Matthew C. Valenti submitted by
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`Petitioners agrees with the facts, analysis, and conclusions of the expert declaration
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`in the VW IPR. The declaration of Dr. Valenti does not contain any new opinions
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`not included in the VW expert declaration. See Everlight Elecs. Co., v. Document
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`Security Sys., Inc., IPR2018-01260, Paper No. 12 at 6-7 (Nov. 14, 2018) (granting
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`motion for joinder where petitioner submitted separate but substantially identical
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`expert declaration).
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`Attorney Docket No: 18768-0206IP1
`interest relating to the unpatentability of the ’512 patent and not cause any undue
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`prejudice to Patent Owner or the VW IPR Petitioner. The Patent Owner must
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`respond to the common invalidity grounds identified in the VW and Petitioners’
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`Petitions regardless of joinder.
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`2.
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`Petitioners’ Petition Does Not Raise Any New Grounds of
`Unpatentability and Therefore Does Not Add Additional
`Complexity to the Grounds in the VW IPR
`Petitioners’ Petition challenges the validity of the ’512 patent on identical
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`grounds to those in the VW IPR. See IPR2022-01539, Paper 1 (September 15,
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`2022). Petitioners’ supporting materials―including its supporting expert
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`declaration, exhibits, and exhibit numbering―are
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`substantially
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`and
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`substantively identical to those presented in the VW IPR. See supra. While
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`Petitioners use their own expert declarant, the expert’s declaration agrees with and
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`adopts the facts, analysis, and conclusions of the expert declaration in the VW IPR
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`and does not contain any new opinions not included in the VW IPR expert
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`declaration. See Everlight Elecs. Co., v. Document Security Sys., Inc., IPR2018-
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`01260, Paper No. 12 at 6-7 (Nov. 14, 2018) (granting motion for joinder where
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`petitioner submitted separate but substantially identical expert declaration).
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`Further, unity of exhibits and exhibit numbering with the VW IPR has been
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`maintained. Accordingly, no new grounds are being introduced. See Sony Corp.
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`v. Memory Integrity, LLC., IPR2015-01353, Paper No. 11 at 5-6 (PTAB Oct. 5,
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`Attorney Docket No: 18768-0206IP1
`2015) (granting motion for joinder where petitioners relied “on the same prior art,
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`same arguments, and same evidence, including the same expert and a substantively
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`identical declaration”).
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`Therefore, consolidation of this proceeding with VW’s via joinder of
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`Petitioners’ 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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`Joinder Will Not Affect the Schedule in the VW IPR
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`3.
`Given that the Board recently instituted review of the VW IPR, joinder of
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`Petitioners would not affect the schedule in any forthcoming trial. Petitioners
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`participation should result in no changes to the schedule.
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`Petitioners agree to adhere to all applicable deadlines set forth in the VW
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`IPR Scheduling Order. The Patent Owner’s Response will not be affected because
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`the issues in Petitioners’ Petition are identical to those in the VW 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 Petitioners Have
`Agreed to Consolidated Filings and an Understudy Role if
`the VW Petitioner Remains
`To further prevent joinder from imposing any burden on the VW IPR
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`Petitioner, Patent Owner, or the Board and to further ensure that there are no
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`changes in the potential trial schedule, Petitioners have agreed, as long as the VW
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`IPR Petitioner remains a party to the VW IPR, to take an understudy role, which
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`will simplify briefing and discovery. In this role, Petitioners agree to the following
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`conditions:
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`(a)
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`Petitioners shall not make any substantive filing and shall be bound
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`by the filings of the VW IPR Petitioner, unless a filing concerns termination and
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`settlement, or issues solely involving Petitioners;
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`(b)
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`Petitioners shall not present any argument or make any presentation
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`at oral hearing unless an issue solely involves Petitioners, or when addressing
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`Board-approved motions that do not affect the VW IPR Petitioner, or its respective
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`position;
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`(c)
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`Petitioners 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 Petitioners;
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`(d)
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`Petitioners shall not seek discovery from Patent Owner on issues not
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`solely involving Petitioners;
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`(e)
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`Petitioners will not rely on expert testimony beyond that submitted
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`by the VW IPR Petitioner unless the VW IPR Petitioner is terminated from the
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`case prior to any necessary depositions. If the VW IPR Petitioner is not terminated
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`from the case prior to any necessary depositions, Petitioners agree to rely entirely
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`on, and be bound by, the expert declarations and depositions in the VW IPR.
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`Petitioners’ expert declaration of Dr. Matthew C. Valenti is substantively identical
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`to the declaration filed in the VW IPR petition. See, e.g., Noven Pharm., Inc. v.
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`Novartis AG, IPR2014-00550, Paper 38 at 5 (PTAB April 10, 2015). Unless and
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`until the current petitioner in IPR2022-01539 ceases to participate in the instituted
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`VW IPR, Petitioners will not assume an active role.2
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`Accordingly, due to Petitioners taking only an “understudy” role, Patent
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`Owner and the VW IPR Petitioner will only need to respond to one principal set
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`of papers, will not require additional time to address additional arguments, and can
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`thus proceed with the existing trial schedule. These steps will minimize or
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`eliminate any potential complications or delay that could potentially result from
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`joinder. See Sony, Paper No. 11 at 6-7 (granting motion because “joinder would
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`increase efficiency by eliminating duplicative filings and discovery, and would
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`reduce costs and burdens on the parties as well as the Board” where second
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`petitioner agreed to “understudy” role). Petitioners will also abide by any
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`additional conditions the Board deems appropriate for an “understudy” role.
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`5.
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`Joinder Will Result in No Prejudice to Patent Owner
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`2 For clarity, should the VW IPR Petitioner’s participation in the VW IPR
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`terminate, Petitioners would take over primary responsibility for subsequent filings
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`and discovery.
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`Attorney Docket No: 18768-0206IP1
`As noted above, Petitioners’ joining of the VW 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 evidence or issues are being added, and no additional
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`discovery or briefing or oral argument should be necessary as a result of
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`Petitioners’ joinder. Thus, Patent Owner would not need to expend any additional
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`resources beyond those required in the current VW 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 Petitioners have not previously
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`challenged the ’512 patent and seek to join the VW IPR in an understudy role. See
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`General Plastic Industrial Co., Ltd. v. Canon Kabushiki Kaisha, IPR2016-01357,
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`Paper 19 at 15-19 (PTAB Sept. 6, 2017); Apple Inc. v. Uniloc 2017 LLC, IPR2020-
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`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, Petitioners have not previously filed a
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`petition against the ’512 patent.
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`Petitioners and the VW IPR Petitioner are separate, unrelated petitioners,
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`and are not similarly situated for purposes of Factor 1. While Petitioners and the
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`VW IPR Petitioner are co-defendants in different (now consolidated) district court
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`litigations, they are not accused of infringing the ’512 Patent based on sale of the
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`same products. Nor has Petitioners or the VW IPR Petitioner provided any
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`products or technology to the other leading to an allegation of infringement of the
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`’512 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, Petitioners
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`did not previously file a first petition prior to its current petition, and while
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`Petitioners previously became aware of the prior art references in the VW IPR as
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`of at least the time of its filing, they made no serial attack on the ’512 patent and
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`have filed this petition for IPR within the one-month time period under 37 C.F.R.
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`§ 42.122(b). These factors weigh in favor of institution and against discretionary
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`denial.
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`Factor 3: As Petitioners did not previously file a first petition this factor
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`weighs in favor of institution and against discretionary denial.
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`Factors 6 and 7: As stated above, Petitioners seek to join the VW IPR and
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`are not raising arguments beyond those raised by the VW petition. These factors
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`thus weigh in favor of institution, as there should be no material impact on the
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`Board’s finite resources or its ability to issue a final determination on the VW
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`petition within one year.
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`INSTITUTION IS APPROPRIATE UNDER FINTIV
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`IV.
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`For the reasons explained in more detail below, and in Petitioners’ Petition,
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`the Fintiv factors weigh in favor of grant of this Motion for Joinder and institution
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`of the concurrently-filed Petition, and even more so because Petitioners merely
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`seek to join an instituted IPR with a petition that relies on the same prior art
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`references and grounds set forth in the instituted IPR.
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`Factor 1 is neutral or favors institution. Following institution of
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`IPR2022-01539, Petitioner, as part of a joint defense group, filed a motion to
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`staying pending IPR of the ’512 patent. See In re Neo Wireless, LLC Patent
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`Litig., 2:22-md-3034-TGB, Dkt. 145 (E.D. MI, May 17, 2023). The court has
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`yet to rule on the motion. Accordingly, Factor 1 is either neutral or weighs
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`against discretionary denial.
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`Factor 2 favors institution because the EDMI litigation is in early
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`stages, no trial date has been set, and the median time to trial for civil actions
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`in EDMI is 46.8 months. EX1034, 40; see June 2022 Memo, 3 (explaining that
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`under factor 2 “the PTAB will consider the median time from filing to
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`disposition of the civil trial for the district in which the parallel litigation
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`resides”). Thus, trial would likely occur (if at all) in early 2026—years after
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`the Board’s projected deadline for a final decision here. See Mylan Pharma.
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`Inc. v. Bayer Pharma. Aktiengesellschaft, IPR2022-00517, Paper 15 at 8-9
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`(P.T.A.B. Aug. 9, 2022).
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`Factor 3 favors institution because, at institution, neither the parties nor
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`the court will have invested significant resources in the parallel litigation.
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`Currently, the court has not issued a scheduling order, or any substantive
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`rulings. Other than claim construction briefs being exchanged and a Markman
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`hearing set for June 21, 2023, no substantive progress has been made in the
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`litigation. Petitioner reserves the right to update the Board should the
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`circumstances change before the institution deadline.
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`Factor 4 favors institution. Petitioner stipulates that, if the Board
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`institutes this Petition, Petitioner will not raise at trial in the parallel litigation
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`any invalidity challenges based on the prior art asserted here. This
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`significantly mitigates the concerns for duplication and inconsistent
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`conclusions embodied in factor 4.
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`Factor 5 is neutral or weighs against discretionary denial. Taking the
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`relevant circumstances into account, including the unique nature of the grounds
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`raised in the Petition, Petitioner’s status as joint defendants in District Court is
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`at worst a neutral factor. See Snap, Inc. v. SRK Technology LLC, IPR2020-
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`00820 Pap. 15 at 16 (PTAB Oct. 21, 2020) (precedential); Sand Revolution II,
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`LLC v. Cont’l Intermodal Group – Trucking LLC, IPR2019-01393, Paper 24 at
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`11-12 (PTAB June 16, 2020). Moreover, institution would promote judicial
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`efficiency and integrity by potentially relieving the District Court of the need
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`to conduct trial, and by enabling the Board to determine invalidity of claims
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`that Patent Owner has serially asserted.
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`Factor 6 favors institution because the merits of the Petition are strong.
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`See supra; June 2022 Memo, 3-5. Other considerations favoring institution
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`under factor 6 include: Further, (1) the Board is best suited to address the
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`technical issues raised here; (2) a decision on the merits at institution may aid
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`the parties in resolving their disputes through alternative dispute resolution;
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`and (3) a patentability ruling will benefit the public by providing a complete
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`record and rationale absent from a black box jury verdict form, such as by
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`deterring future litigation. Patent Owner has filed suit against nine defendants
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`and is likely to file against others given the remaining patent term of the ’512
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`patent and Patent Owner’s allegations that the ’512 patent is essential to certain
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`telecommunication standards. Considered holistically, the Fintiv factors
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`strongly favor IPR.
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`V. CONCLUSION
`For the foregoing reasons, Petitioners respectfully request that their Petition
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`for Inter partes review of the ’512 Patent be instituted and that Petitioners be joined
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`to the VW IPR proceeding IPR2022-01539.
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`Dated June 2, 2023
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`Case IPR2023-00961
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`Respectfully submitted,
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`/Timothy W. Riffe/
`Timothy Riffe, Reg. No. 43,881
`Usman Khan, Reg. No. 70,439
`Fish & Richardson P.C.
`60 South Sixth Street, Suite 3200
`Minneapolis, MN 55402
`T: 202-783-5070
`F: 877-769-7945
`
`Reginald J. Hill, Reg. No. 39,225
`Nicole A. Keenan, Reg. No. 48,622
`JENNER & BLOCK LLP
`353 N. Clark Street
`Chicago, IL 60654
`Phone: (312) 923-2606
`Fax: (312) 527-0484
`
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`Attorneys for Petitiones
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 CFR § 42.6(e), the undersigned certifies that on June 2, 2023,
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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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`VOLPE KOENIG
`30 SOUTH 17TH STREET, 18TH FLOOR
`PHILADELPHIA, PA 19103
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`/Diana Bradley/
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`Diana Bradley
`Fish & Richardson P.C.
`60 South Sixth Street, Suite 3200
`Minneapolis, MN 55402
`(858) 678-5667
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