UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`GENERAL MOTORS LLC, ET AL.,
`Petitioner,
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`v.
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`NEO WIRELESS, LLC,
`Patent Owner.
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`IPR2023-00964
`Patent No. 10,075,941
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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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`GENERAL MOTORS LLC, ET AL.,
`Petitioner,
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`v.
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`NEO WIRELESS, LLC,
`Patent Owner.
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`IPR2023-00964
`Patent No. 10,075,941
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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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`Proceeding No. IPR2023-00964
`Attorney Docket No: 18768-0206IP4
`STATEMENT OF PRECISE RELIEF REQUESTED
`General Motors LLC, Nissan North America, Inc., and Tesla, Inc.
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`(collectively “Petitioner” or “Petitioners”) respectfully submit this Motion for
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`Joinder, concurrently with a Petition for inter partes review of U.S. Patent No.
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`10,075,941 (“the ‘941 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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`Petitioner requests institution of an inter partes review and joinder with IPR2022-
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`01537 (Volkswagen Group of America, Inc. v. Neo Wireless LLC “Volkswagen
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`IPR”), instituted on May 5, 2023 (Paper 8). Petitioner’s concurrently-filed petition
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`is substantively the same as the Volkswagen 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
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`Volkswagen IPR and therefore would create no additional burden for the Board, the
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`Volkswagen IPR Petitioner, or Patent Owner if joined. Joinder would therefore lead
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`to an efficient resolution of the validity of the ’941 patent.
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`Petitioners are currently named as defendants in In re Neo Wireless LLC
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`Patent Litig., 2-22-cv-00094 (E.D. MI). In this proceding, Petitioners have been
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`accused of infringing the ’941 patent. Petitioners have not previously filed a petition
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`for IPR challenging the validity of the ’941 patent.
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`Petitioners stipulate that if joinder is granted, they will act as an “understudy”
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`and will not assume an active role unless the Volkswagen IPR Petitioner ceases to
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`1
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`Proceeding No. IPR2023-00964
`Attorney Docket No: 18768-0206IP4
`participate in the proceeding. The Volkswagen IPR Petitioner will maintain the lead
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`role in the proceeding so long as it remains in the proceeding. These limitations will
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`avoid lengthy and duplicative briefing. Petitioners also will not seek additional
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`depositions or deposition time. Joinder will not impact the trial schedule because
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`the proceeding based on the Volkswagen IPR is in its early stages having just
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`instituted on May 5, 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 Volkswagen
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`IPR for all interested parties.
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`Joinder will not unduly prejudice any party. Because joinder will not add any
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`new substantive issues, delay the schedule, burden deponents, or needlessly increase
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`filings, any additional costs on Patent Owner will be minimal. On the other hand,
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`denial of joinder would prejudice Petitioners. Petitioners’ interests may not be
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`adequately protected in the Volkswagen IPR, particularly if the Volkswagen IPR
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`Petitioner settles with Patent Owner and ceases to participate. Petitioners should be
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`allowed to join 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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`Petitioners’ cooperative participation in the Volkswagen IPR in the event that the
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`Volkswagen IPR Petitioner’s participation terminates, the Board should institute
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`2
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`Proceeding No. IPR2023-00964
`Attorney Docket No: 18768-0206IP4
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`IPR and grant Petitioners’ 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., IPR2013-00385, 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 Volkswagen IPR insitituted on May 5, 2023, IPR2022-01537, Paper 8.
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`Petitioners’ current motion is timely as it is being filed within one month of the
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`3
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`Proceeding No. IPR2023-00964
`Attorney Docket No: 18768-0206IP4
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`date of institution.
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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
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`Volkswagen IPR; it presents no new grounds of unpatentability. Joinder will have
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`no impact on the pending schedule of the Volkswagen IPR. Moreover, the briefing
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`and discovery 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
`’941 Patent Without Prejudice to Any Party
`Petitioners seeks to join the Volkswagen IPR in order to ensure that an
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`accused infringer with an active interest in the proceeding remains a party to this
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`IPR if the Volkswagen IPR Petitioner’s participation is terminated prior to
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`completion. Thus, joining Petitioners to the Volkswagen IPR is the most practical
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`way to secure the just, speedy, and inexpensive resolution of the challenge to the
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`’941 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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`Volkswagen IPR can be determined in a single proceeding. Joinder is also
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`appropriate because Petitioners’ petition challenges the validity of the same claims
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`of the ’941 patent on identical grounds to those in the Volkswagen IPR. There are
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`no substantive differences between Petitioners’ and the Volkswagen IPR
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`4
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`Proceeding No. IPR2023-00964
`Attorney Docket No: 18768-0206IP4
`Petitioner’s Petition, IPR2022-01537, Paper 1 (September 15, 2022). Petitioners
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`also rely on substantially the same supporting evidence in their Petition as is relied
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`on in the Volkswagen IPR.1 A consolidated proceeding, including Petitioners and
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`the Volkswagen IPR Petitioner, will therefore be more efficient and less wasteful,
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`as only a single trial on these common grounds would be required. See, e.g.,
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`Oracle America Inc. v. Realtime Data LLC, IPR2016-01672, Paper 13 at 7 (PTAB
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`Mar. 7, 2017) (noting that “joining Oracle’s identical challenges to those in the
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`1002 IPR will lead to greater efficiency while reducing the resources necessary
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`from both Realtime and the Board”). The Board “routinely grants motions for
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`joinder where the party seeking joinder introduces identical arguments and the
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`same grounds raised in the existing proceeding.” Samsung Elecs. Co., Ltd. v.
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`Raytheon Co., IPR2016-00962, Paper 12 at 9 (PTAB Aug. 24, 2016) (internal
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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 Volkswagen IPR. The declaration of Dr. Valenti does not contain any new
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`opinions not included in the Volkswagen IPR expert declaration. See Everlight
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`Elecs. Co., v. Document Security Sys., Inc., IPR2018-01260, Paper No. 12 at 6-7
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`(Nov. 14, 2018) (granting motion for joinder where petitioner submitted separate
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`but substantially identical expert declaration).
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`5
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`Proceeding No. IPR2023-00964
`Attorney Docket No: 18768-0206IP4
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`quotations and citations omitted).
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`Joining Petitioners as a party to the Volkswagen IPR would promote the
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`public interest relating to the unpatentability of the ’941 patent and not cause any
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`undue prejudice to Patent Owner or the Volkswagen IPR Petitioner. The Patent
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`Owner must respond to the common invalidity grounds identified in the
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`Volkswagen and Petitioners’ 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 Volkswagen IPR
`Petitioners’ Petition challenges the validity of the ’941 patent on identical
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`grounds to those in the Volkswagen IPR. See IPR2022-01537, Paper 1 (September
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`15, 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 Volkswagen IPR. See supra
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`n.2. While Petitioners use their own expert declarant, the expert’s declaration
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`agrees with the facts, analysis, and conclusions of the expert declaration in the
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`Volkswagen IPR and does not contain any new opinions not included in the
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`Volkswagen IPR 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). Further, unity of exhibits and exhibit numbering with the
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`6
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`Proceeding No. IPR2023-00964
`Attorney Docket No: 18768-0206IP4
`Volkswagen IPR has been maintained. Accordingly, no new grounds are being
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`introduced. See Sony Corp. v. Memory Integrity, LLC., IPR2015-01353, Paper No.
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`11 at 5-6 (PTAB Oct. 5, 2015).
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`Therefore, consolidation of this proceeding with Volkswagen’s via joinder
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`of 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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`3.
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`Joinder Will Not Affect the Schedule in the Volkswagen
`IPR
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`Given that the Board just recently instituted the Volkswagen IPR, joinder
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`of Petitioners would not affect the schedule in any potential forthcoming trial.
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`Petitioners’ 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
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`Volkswagen IPR Scheduling Order. The Patent Owner’s Response will not be
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`affected because the issues in Petitioners’ Petition are identical to those in the
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`Volkswagen IPR petition. Patent Owner will thus not be required to provide any
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`additional analysis or 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 Volkswagen Petitioner Remains
`To further prevent joinder from imposing any burden on the Volkswagen
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`IPR Petitioner, Patent Owner, or the Board and to further ensure that there are no
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`7
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`Proceeding No. IPR2023-00964
`Attorney Docket No: 18768-0206IP4
`changes in the potential trial schedule, Petitioners have agreed, as long as the
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`Volkswagen IPR Petitioner remains a party to the Volkswagen IPR, to take an
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`understudy role, which will simplify briefing and discovery. In this role,
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`Petitioners agree to the following 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 Volkswagen IPR Petitioner, unless a filing concerns
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`termination and 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 Volkswagen IPR Petitioner, or its
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`respective 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 Volkswagen IPR Petitioner unless the Volkswagen IPR Petitioner is
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`terminated from the case prior to any necessary depositions. If the Volkswagen IPR
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`Petitioner is not terminated from the case prior to any necessary depositions,
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`8
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`Proceeding No. IPR2023-00964
`Attorney Docket No: 18768-0206IP4
`Petitioners agree to rely entirely on, and be bound by, the expert declarations and
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`depositions in the Volkswagen IPR. Petitioners’ expert declaration of Dr. Matthew
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`C. Valenti is substantively identical to the Wilson declaration filed by the
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`Volkswagen IPR Petitioner. Dr. Valenti would not be relied on if the Volkswagen
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`IPR Petitioner continues to participate in the Volkswagen IPR. See, e.g., Noven
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`Pharm., Inc. v. Novartis AG, IPR2014-00550, Paper 38 at 5 (PTAB April 10,
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`2015). Unless and until the current petitioner in IPR2022-01537 ceases to
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`participate in the instituted Volkswagen IPR, Petitioners will not assume an active
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`role.2
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`Accordingly, due to Petitioners taking only an “understudy” role, Patent
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`Owner and the Volkswagen IPR Petitioner will only need to respond to one
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`principal set of papers, will not require additional time to address additional
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`arguments, and can thus proceed with the existing trial schedule. These steps will
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`minimize or eliminate any potential complications or delay that could potentially
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`result from joinder. See Sony, Paper No. 11 at 6-7 (granting motion because
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`“joinder would increase efficiency by eliminating duplicative filings and
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`2 For clarity, should the Volkswagen IPR Petitioner’s participation in the
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`Volkswagen IPR terminate, Petitioners would take over primary responsibility for
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`subsequent filings and discovery.
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`9
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`Proceeding No. IPR2023-00964
`Attorney Docket No: 18768-0206IP4
`discovery, and would reduce costs and burdens on the parties as well as the Board”
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`where second petitioner agreed to “understudy” role). Petitioners will also abide
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`by any additional conditions the Board deems appropriate for an “understudy”
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`role.
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`5.
`Joinder Will Result in No Prejudice to Patent Owner
`As noted above, Petitioners’ joining of the Volkswagen IPR proceeding
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`should not result in any prejudice to Patent Owner. No additional grounds or
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`arguments are being introduced, no new evidence or issues are being added, and
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`no additional discovery or briefing or oral argument should be necessary as a result
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`of Petitioners’ joinder. Thus, Patent Owner would not need to expend any
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`additional resources beyond those required in the current Volkswagen 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 ’941 patent and seeks to join the Volkswagen IPR in an understudy
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`role. See General Plastic Industrial Co., Ltd. v. Canon Kabushiki Kaisha,
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`IPR2016-01357, Paper 19 at 15-19 (PTAB Sept. 6, 2017); Apple Inc. v. Uniloc
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`2017 LLC, IPR2020-00224, Paper 10 at 4-5 (PTAB Apr. 6, 2020).
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`Factor 1: 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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`10
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`Proceeding No. IPR2023-00964
`Attorney Docket No: 18768-0206IP4
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`petition against the ’941 patent.
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`Petitioners and the Volkswagen IPR Petitioner are separate, unrelated
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`petitioners, and are not similarly situated for purposes of Factor 1. While
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`Petitioners and the VW IPR Petitioner are co-defendants in different (now
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`consolidated) district court litigations, they are not accused of infringing the ’941
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`Patent based on sale of the same products. Nor has Petitioners or the Volkswagen
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`IPR Petitioner provided any products or technology to the other leading to an
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`allegation of infringement of the ’941 Patent. This factor weighs in favor of
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`institution and against discretionary denial.
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`Factors 2, 4 and 5: As to the timing examined in these factors, Petitioners
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`did not previously file a first petition prior to its current petition, and while
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`Petitioners became aware of the prior art references in the Volkswagen IPR as of
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`at least the time of its filing, they made no serial attack on the ’941 patent and have
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`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 Volkswagen
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`IPR and are not raising arguments beyond those raised by the Volkswagen petition.
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`11
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`Proceeding No. IPR2023-00964
`Attorney Docket No: 18768-0206IP4
`These factors thus weigh in favor of institution, as there should be no material
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`impact on the Board’s finite resources or its ability to issue a final determination
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`on the Volkswagen 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 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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`IPR2022-01537, Petitioners, as part of a joint defense group, filed motions to
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`staying pending IPR of the ’941 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. EX1045, 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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`12
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`Proceeding No. IPR2023-00964
`Attorney Docket No: 18768-0206IP4
`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 neither the parties nor the court have
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`invested significant resources in the parallel litigation. The court has not issued
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`a scheduling order, or any substantive rulings. Other than claim construction
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`briefs being exchanged and a Markman hearing set for June 21, 2023, no
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`substantive progress has been made in the litigation.
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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, Petitioners’ 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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`13
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`Proceeding No. IPR2023-00964
`Attorney Docket No: 18768-0206IP4
`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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`as indicated by the fact that the VW IPR (IPR2022-01537), which Petitioners
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`seek to join has already been instituted. See supra; June 2022 Memo, 3-5.
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`Other considerations favoring institution under factor 6 include: Further, (1)
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`the Board is best suited to address the technical issues raised here; (2) a
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`decision on the merits at institution may aid the parties in resolving their
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`disputes through alternative dispute resolution; and (3) a patentability ruling
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`will benefit the public by providing a complete record and rationale absent
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`from a black box jury verdict form, such as by deterring future litigation.
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`Patent Owner has filed suit against nine defendants and is likely to file against
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`others given the remaining patent term of the ’941 patent and Patent Owner’s
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`allegations that the ’941 patent is essential to certain telecommunication
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`standards. Considered holistically, the Fintiv factors 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 ’941 Patent be instituted and that Petitioners be joined
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`14
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`Proceeding No. IPR2023-00964
`Attorney Docket No: 18768-0206IP4
`to the Volkswagen IPR proceeding IPR2022-01537.
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`Dated: June 5, 2023
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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 Petitioner
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`15
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`Proceeding No. IPR2023-00964
`Attorney Docket No: 18768-0206IP4
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 CFR § 42.6(e), the undersigned certifies that on June 5, 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/
`
`Diana Bradley
`Fish & Richardson P.C.
`60 South Sixth Street, Suite 3200
`Minneapolis, MN 55402
`(858) 678-5667
`
`
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