UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_______________________
`
`EBAY, INC.,
`
`Petitioner,
`
`v.
`
`LEXOS MEDIA IP, LLC,
`
`Patent Owner.
`
`_______________________
`
`Case IPR2024-00336
`
`U.S. Patent No. 5,995,102
`
`_______________________
`
`MOTION FOR JOINDER TO
`INTER PARTES REVIEW IPR2023-01000
`
`
`
`
`
`
`
`
`
`
`_______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_______________________
`
`EBAY, INC.,
`
`Petitioner,
`
`v.
`
`LEXOS MEDIA IP, LLC,
`
`Patent Owner.
`
`_______________________
`
`Case IPR2024-00336
`
`U.S. Patent No. 5,995,102
`
`_______________________
`
`MOTION FOR JOINDER TO
`INTER PARTES REVIEW IPR2023-01000
`
`
`
`
`
`
`
`
`
`
`
`
`TABLE OF CONTENTS
`STATEMENT OF THE PRECISE RELIEF REQUESTED ..................... 1
`I.
`STATEMENT OF MATERIAL FACTS ................................................... 2
`II.
`STATEMENT OF REASONS FOR RELIEF REQUESTED ................... 2
`III.
`Legal Standard ............................................................................................ 2
`A.
`Petitioner’s Motion for Joinder is Timely .................................................. 3
`B.
`Each Factor Weighs in Favor of Joinder .................................................... 3
`C.
`Joinder is Appropriate with the Amazon IPR .............................................. 6
`1.
`2. Petitioner Proposes No New Grounds of Unpatentability ........................... 7
`3.
`Joinder Will Not Unduly Burden or Negatively Impact the Amazon IPR
`Trial Schedule ........................................................................................ 8
`4. Procedures to Simplify Briefing and Discovery .......................................... 9
`GENERAL PLASTIC IS INAPPLICABLE AND FAVORS
`IV.
`PETITIONER ........................................................................................................... 11
`V.
`CONCLUSION ........................................................................................ 13
`
`
`
`ii
`
`
`
`
`
`I.
`
`STATEMENT OF THE PRECISE RELIEF REQUESTED
`eBay Inc. (“Petitioner”) respectfully submits this Motion for Joinder
`
`(“Motion”) together with a Petition for Inter Partes Review of U.S. Patent No.
`
`5,995,102 (the “eBay Petition”) filed contemporaneously herewith. Pursuant to 35
`
`U.S.C. § 315(c) and 37 C.F.R. § 42.122(b), Petitioner requests institution of an inter
`
`partes review and joinder with the inter partes review in Amazon.com, Inc. v. Lexos
`
`Media IP, LLC, IPR2023-01000 (the “Amazon IPR”) in view of the Patent Trial and
`
`Appeal Board’s (the “Board”) decision to institute trial on December 12, 2023.
`
`(Amazon IPR, Paper 9.) Counsel for eBay has conferred with counsel for
`
`Amazon.com, Inc. (“Amazon”), and counsel for Amazon does not object to eBay
`
`joining IPR2023-01000.
`
`Petitioner’s request for joinder is timely under 37 C.F.R. § 42.122(b) as it is
`
`submitted no later than one month after the December 12, 2023 institution date of
`
`the Amazon IPR. The eBay Petition is also narrowly tailored to the same claim, prior
`
`art, and grounds for unpatentability that are the subject of the Amazon IPR. In
`
`addition, Petitioner is willing to streamline discovery and briefing, as well as follow
`
`the Amazon IPR Scheduling Order.
`
`Petitioner submits that joinder is appropriate because it will not unduly burden
`
`or prejudice the parties to the Amazon IPR while efficiently resolving whether a
`
`1
`
`
`
`
`
`single claim (claim 72) of U.S. Patent No. 5,995,102 (the “’102 Patent”) is valid and
`
`in a single proceeding.
`
`II.
`1.
`
` STATEMENT OF MATERIAL FACTS
`On June 5, 2023, Amazon filed a petition for inter partes review in
`
`IPR2023-01000 requesting cancellation of claim 72 of the ʼ102 Patent.
`
`2.
`
`On June 22, 2022, Lexos Media IP, LLC (“Lexos” or “Patent Owner”)
`
`filed a civil action against eBay, Inc., Case No. 6:22-cv-00648, in the United States
`
`District Court for the Western District of Texas (“the Western District Case”). Patent
`
`Owner filed a second amended complaint in the Western District Case on May 16,
`
`2023.
`
`3.
`
`On December 6, 2023, Judge Albright issued an Order granting
`
`Petitioner eBay’s request to transfer venue from the Western District of Texas to the
`
`Northern District of California. The Northern District of California litigation is
`
`pending, and is stylized Lexos Media IP, LLC v. eBay, Inc., No. 3:23-cv-06314-LJC
`
`(N.D. Cal.) (the “Northern District Litigation”).
`
`4.
`
`On December 12, 2023, the Board instituted Amazon’s petition for
`
`inter partes review in IPR2023-01000, finding that “there is a reasonable likelihood
`
`that Petitioner would prevail with respect to claim 72 on at least one of the grounds
`
`raised in the Petition.” Amazon IPR, Paper 9 at 36.
`
`III. STATEMENT OF REASONS FOR RELIEF REQUESTED
`A. Legal Standard
`
`2
`
`
`
`
`
`The Board has the authority under 35 U.S.C. § 315(c) to join a properly filed
`
`inter partes review petition to an instituted inter partes review proceeding. See 35
`
`U.S.C. § 315(c). A motion for joinder must be filed within one month of the Board
`
`instituting an original inter partes review. 37 C.F.R. § 42.122(b). In deciding
`
`whether to exercise its discretion and permit joinder, the Board considers several
`
`factors, including: (1) the reasons why joinder is appropriate; (2) whether the new
`
`petition presents any new grounds of unpatentability; (3) what impact, if any, joinder
`
`would have on the trial schedule for the existing review; and (4) how briefing and
`
`discovery may be simplified. See Kyocera Corporation v. Softview LLC, IPR2013-
`
`00004, Paper 15 at 4 (April 24, 2013); Patent Trial and Appeal Board Consolidated
`
`Trial Practice Guide (Nov. 2019), 76-78.
`
`B. Petitioner’s Motion for Joinder is Timely
`This Motion for Joinder is timely because it is filed within one month of the
`
`December 12, 2023 institution decision of the Amazon IPR. 37 C.F.R. § 42.122(b).
`
`Further, the one-year bar set forth in 35 U.S.C. § 315(b) and 37 C.F.R. § 42.101(b)
`
`does not apply to the eBay Petition because this Motion for Joinder is filed
`
`concurrently with the eBay Petition. 37 C.F.R. § 42.122(b).
`
`C. Each Factor Weighs in Favor of Joinder
`As explained in detail below, each of the four factors considered by the Board
`
`weighs in favor of joinder. Specifically, the eBay Petition does not present any new
`
`3
`
`
`
`
`
`grounds of unpatentability; rather it is substantively identical to the Amazon Petition.
`
`Further, joinder will have minimal, if any, impact on the trial schedule, as all issues
`
`are substantively identical, and Petitioner eBay will accept an “understudy” role
`
`unless and until Amazon is terminated from the proceeding. Lastly, the briefing and
`
`discovery will be simplified by resolving all issues in a single proceeding.
`
`Accordingly, joinder is appropriate here.
`
`Petitioner notes that Amazon may be in the late stages of settlement
`
`discussions with Patent Owner, as confirmed by the recent dismissal of Amazon
`
`from the corresponding District Court case (Lexos Media IP, LLC v. Amazon.com,
`
`Inc., No. 2:22-cv-00169 (E.D. Tex.)). However, should Amazon and Patent Owner
`
`settle their dispute and seek to terminate the Amazon IPR, Petitioner’s Motion
`
`should still be granted because it is timely presented, the Petition presents a
`
`compelling case of unpatentability, and resolving this dispute is in the interests of
`
`justice.
`
`Indeed, the present circumstances are similar to those of Code200 v. Bright
`
`Data Ltd., IPR2022-00861 (“the Code200 IPR”). There, several petitioners,
`
`including Code200, sought to join IPR2021-01492 (the ’1492 IPR) in much the same
`
`manner as presented here—a petition and motion for joinder were timely filed in the
`
`Code200 IPR and before the ’1492 IPR petitioner and patent owner requested
`
`termination of the ’1492 IPR. The Board originally denied the motion for joinder,
`
`4
`
`
`
`
`
`generally relying on General Plastic grounds. Code200 IPR, Paper 17 at 16 (July
`
`25, 2022). In denying institution, the Board stated:
`
`“Although Petitioner has agreed to an ‘understudy’ role, NetNut, the
`petitioner in the 1492 IPR to be joined, has been terminated from that
`proceeding due to a settlement.… Therefore, Petitioner would not be
`acting in the role of an understudy, but would immediately assume the
`leading role if joinder were granted.… Thus, if we granted joinder here,
`‘Petitioner would stand in to continue a proceeding that would
`otherwise be terminated.’” Id. at 8.
`In stark departure from the norm, Director Vidal sua sponte reviewed the
`
`Code200 IPR institution decision, and vacated and remanded it. Code200, Vidal
`
`Remand (Paper 18) (August 23, 2022). On remand, the Board granted the motion
`
`for joinder and instituted trial despite the ’1492 IPR settlement, noting:
`
`“[W]e determine that the merits of this action present a compelling
`unpatentability challenge. Absent joinder, a one-year bar would apply
`to Petitioner, and, again, the merits presented in this challenge would
`not be reached by the Board in a final written decision. Under these
`specific circumstances, we determine joinder is appropriate in the
`interests of justice.” Code200, Paper 19 at 39 (October 19, 2022).
`The panel continued:
`
`“Because NetNut has been dismissed from the 1492 IPR, there are no
`longer issues of cooperation and duplication that would have to be
`addressed between petitioners.” Id.
`
`5
`
`
`
`
`
`The Board should follow the guidance of the Code 200 IPR tribunal and grant
`
`Petitioner’s Motion even if Amazon and Lexos request termination of the Amazon
`
`IPR. The Amazon IPR petition presents compelling unpatentability challenges,
`
`resolving the merits of the Amazon petition is in the interest of justice, and joinder
`
`is appropriate in such circumstances. Code200, Paper 19 at 39. Moreover, the
`
`PTAB routinely grants motions for joinder in view of pending litigations involving
`
`the same patent and the same parties. See, e.g., Apple Inc. v. Uniloc 2017 LLC,
`
`IPR2020-00224, Paper 10 at 2-7 (PTAB April 6, 2020) (granting motion for joinder
`
`of a copycat petition in view of co-pending lawsuit); Apple Inc. v. INVT SPE LLC,
`
`IPR2019-00958, Paper 9 at 2-13 (PTAB May 30, 2019) (same); Celltrion, Inc. v.
`
`Genentech, Inc., IPR2018-01019, Paper 11 at 2-15 (PTAB Oct. 30, 2018) (same);
`
`Huawei Device Co., Ltd. v. Uniloc Luxembourg S.A., IPR2017-02090, Paper 9 at 2-
`
`12 (PTAB March 6, 2018) (same); Pfizer, Inc. v. Genentech, Inc., IPR2017-02063,
`
`Paper 25 at 4-8 (PTAB Feb. 21, 2018) (same); General Motors LLC v. Neo Wireless
`
`LLC, IPR2023-00963, Paper 10 at 2-20 (PTAB Dec. 6, 2023) (same); T-Mobile
`
`USA, Inc. v. Dali Wireless, Inc., IPR2023-00830, Paper 7 at 2-11 (PTAB Oct. 11,
`
`2023) (same); Cooler Master Co., Ltd. v. Asektek Danmark A/S, IPR2023-00667,
`
`Paper 6 at 2-13 (PTAB Aug. 28, 2023) (same).
`
`1. Joinder is Appropriate with the Amazon IPR
`
`6
`
`
`
`
`
`Joinder with the Amazon IPR is appropriate because the eBay Petition
`
`involves the same patent, challenges the same claim, relies on the same expert
`
`declaration, and is based on the same grounds and combinations of prior art
`
`submitted in the Amazon Petition. The eBay Petition is substantively identical to the
`
`Amazon Petition, containing only minor differences unrelated to the merits of the
`
`proposed grounds. There are no changes to the facts, citations, evidence, or
`
`arguments presented in the Amazon Petition in relation to the grounds of the
`
`Amazon Petition. Because these proceedings are substantively identical, good cause
`
`exists for joining this proceeding with the Amazon IPR so that the Board can
`
`efficiently resolve all grounds in both the eBay and Amazon Petitions in a single
`
`proceeding. Moreover, as explained previously, the Amazon IPR petition presents
`
`compelling unpatentability challenges, resolving the merits of the Amazon petition
`
`is in the interest of justice, and joinder is appropriate in such circumstances.
`
`Code200, Paper 19 at 39.
`
`2. Petitioner Proposes No New Grounds of Unpatentability
`The eBay Petition does not present any new grounds of unpatentability. The
`
`eBay Petition is substantively identical to the Amazon Petition. The eBay Petition
`
`presents the unpatentability of the same claim of the same patent in the same way as
`
`the Amazon Petition. The Board “routinely grants motions for joinder where the
`
`party seeking joinder introduces identical arguments and the same grounds raised in
`
`7
`
`
`
`
`
`the existing proceeding.” Samsung Elecs. Co. v. Raytheon Co., IPR2016-00962,
`
`Paper 12 at 9 (PTAB Aug. 24, 2016) (internal quotations and citations omitted)
`
`(emphasis original); see also STMicroelectronics, Inc. v. Lone Star Silicon
`
`Innovations, LLC, IPR2018-00436, Paper 7 at 5 (PTAB May 4, 2018) (granting
`
`joinder and reasoning, “[w]e rely in particular, on Petitioner’s representation that its
`
`Petition is ‘substantially identical’…challenges the same claims based on the same
`
`prior art and the same grounds of unpatentability….”).
`
`3. Joinder Will Not Unduly Burden or Negatively Impact the
`Amazon IPR Trial Schedule
`Because the eBay Petition is substantively identical to the Amazon Petition,
`
`with the same grounds applied to the same claim as instituted by the Board, there are
`
`no new issues for Patent Owner to address. Due to the same issues being presented
`
`in the Amazon Petition, Patent Owner will not be required to present any additional
`
`responses or arguments. LG v. Memory Integrity, LLC, IPR2015-01353, Paper 11,
`
`at 6 (Oct. 5, 2015) (granting IPR and motion for joinder where “joinder should not
`
`necessitate any additional briefing or discovery from Patent Owner beyond that
`
`already required in [the original IPR].”); see also id., Paper 4 at 5–7.
`
`The Patent Owner Response will also not be negatively impacted because the
`
`issues presented in the Amazon Petition are identical to the issues presented in the
`
`eBay Petition. Patent Owner will not be required to provide any additional analysis
`
`or arguments beyond what it will already provide in responding to the Amazon
`
`8
`
`
`
`
`
`Petition. Also, because the eBay Petition relies on the same expert and a
`
`substantively identical declaration, only a single deposition is needed for the
`
`proposed joined proceeding.1
`
`Joinder of this proceeding with the Amazon IPR would not unduly burden or
`
`negatively impact the trial schedule in any meaningful way. Further, even if a small
`
`adjustment of the trial schedule was necessary, this is already provided for in the
`
`rules and is a routine undertaking by parties in IPR proceedings. See 37 C.F.R. §
`
`42.100(c). Thus, a slight adjustment in the trial schedule, should one be needed, is
`
`not enough of a reason to deny joining the present eBay Petition with the Amazon
`
`IPR.
`
`4. Procedures to Simplify Briefing and Discovery
`The Amazon Petition and the eBay Petition present substantively identical
`
`grounds of rejection, including the same art combinations against the same claim.
`
`Additionally, Petitioner explicitly agrees to take an “understudy” role, as described
`
`by the Board:
`
`“(a) all filings by [Petitioner] in the joined proceeding be consolidated
`with [the filings of the petitioner in the Amazon IPR], unless a filing
`
`
`1 Petitioner eBay has engaged Dr. Rosenberg, Amazon’s expert for the Amazon IPR.
`
`Petitioner eBay has submitted Dr. Rosenberg’s declaration from the Amazon IPR
`
`with the eBay IPR petition in unaltered form, except for exhibit labeling.
`
`9
`
`
`
`
`
`solely concerns issues that do not involve [the petitioner in the Amazon
`IPR]; (b) [Petitioner] shall not be permitted to raise any new grounds
`not already instituted by the Board in the [Amazon IPR], or introduce
`any argument or discovery not already introduced by [the petitioner in
`the Amazon IPR]; (c) [Petitioner] shall be bound by any agreement
`between [Patent Owner] and [the petitioner in the Amazon IPR]
`concerning discovery and/or depositions; and (d) [Petitioner] at
`deposition shall not receive any direct, cross-examination or redirect
`time beyond that permitted for [the petitioner in the Amazon IPR] alone
`under either 37 C.F.R. § 42.53 or any agreement between [Patent
`Owner] and [the petitioner in the Amazon IPR].”
`
`See IPR2014-00550, paper 38 at 5 (Apr. 10, 2015).
`
`Petitioner eBay will assume the primary role only if Amazon ceases to
`
`participate in the Amazon IPR. Counsel for eBay has conferred with counsel for
`
`Amazon, and Amazon does not object to Petitioner eBay joining IPR2023-01000 in
`
`an “understudy” role. By Petitioner accepting an “understudy” role, Patent Owner
`
`and Petitioner eBay can comply with the current trial schedule and avoid any
`
`duplicative efforts by the Board or the Patent Owner. These steps will minimize any
`
`potential complications or delay that may result due to joinder. See, e.g., Garmin
`
`Int’l, Inc. v. Philips North Am. LLC, IPR2020-00910, Paper 8 at 45, 47-50 (PTAB
`
`Nov. 19, 2020) (granting joinder where petitioners agreed to accept an “understudy”
`
`role); STMicroelectronics, IPR2018-00436, Paper 7 at 5 (similar).
`
`10
`
`
`
`
`
`IV. GENERAL PLASTIC IS GENERALLY INAPPLICABLE AND
`FAVORS PETITIONER
`In General Plastic, the Board sets forth a series of factors that may be
`
`analyzed for follow-on petitions to help conserve the finite resources of the Board.
`
`However, Petitioner respectfully submits that the General Plastic analysis is
`
`inapplicable here. In the current motion, eBay merely seeks to join Amazon’s
`
`proceeding in an understudy rule and does not present any new grounds. The PTAB
`
`has previously found that such circumstances “effectively neutralize[]” a General
`
`Plastic analysis. See Apple Inc. v. Uniloc 2017 LLC, IPR2018-00580, Paper 13 at 10
`
`(PTAB Aug. 21, 2018) (instituting a joinder copycat petition where petitioner agreed
`
`to assume a passive understudy role, and noting such circumstances “effectively
`
`neutraliz[es] the General Plastic factors”); see also Celltrion, Inc. v. Genetech, Inc.,
`
`IPR2019-01019, Paper 11 at 10 (PTAB Oct. 30, 2018) (noting the joinder motion
`
`“effectively obviates any concerns of serial harassment and unnecessary
`
`expenditures of resources”) and Code200, Vidal Remand (Paper 18) (finding road-
`
`mapping and other General Plastic concerns generally inapplicable or of limited
`
`relevance when a motion for joinder presents a copycat petition).
`
`In any event, the General Plastic factors counsel heavily against discretionary
`
`denial, i.e., in favor of instituting the present IPR and joining it with the Amazon
`
`IPR. General Plastic Indus. Co., Ltd. v. Canon Kabushiki Kaisha, IPR2016-01357,
`
`slip op. at 16 (PTAB Sept. 6, 2017) (Paper 19) (precedential as to § II.B.4.i).
`
`11
`
`
`
`
`
`The first three General Plastic factors all strongly favor Petitioner. Petitioner
`
`has not previously filed an IPR challenge to the ’102 patent, Petitioner has included
`
`a Sotera stipulation in its Petition, and there are no road-mapping concerns as
`
`Petitioner has simply filed a copycat version of the Amazon Petition. These factors
`
`all counsel against discretionary denial. Code200, Vidal Remand (Paper 18) at 4-6.
`
`The fourth, fifth and seventh General Plastic factors have limited relevance
`
`when a motion for joinder with a copycat petition is presented. Code200, Vidal
`
`Remand (Paper 18) at 6. In any event, those factors favor Petitioner as the instant
`
`Motion is being filed within eight days of institution of the Amazon IPR and there
`
`should be no delay in the Amazon IPR if Petitioner’s Motion is granted.
`
`The sixth factor also favors Petitioner as it is “the Board’s ‘mission to improve
`
`patent quality and restore confidence in the presumption of validity that comes with
`
`issued patents’” which “outweighs the impact on Board resources needed to evaluate
`
`the merits of a petition.” Code200, Vidal Remand (Paper 18) at 6, citing Cuozzo
`
`Speed Techs., LLC v. Lee, 579 U.S. 261, 272 (2016).
`
`Accordingly, all of the General Plastic factors counsel against discretionary
`
`denial and in favor granting of Petitioner’s Motion. Indeed, any “concerns of
`
`fairness are outweighed by the benefits to the patent system of improving patent
`
`quality by reviewing the merits of the challenges raised in the petition[], which have
`
`not been addressed to date.” Code200, Vidal Remand (Paper 18) at 6, citing General
`
`12
`
`
`
`
`
`Plastic at 16 (citing H.R. Rep. No. 112-98, pt. 1, at 40 (2011)); see also Samsung
`
`Elecs. Am., Inc. v. Uniloc Lux. S.A., IPR2017-01797, Paper 8 at 33 (P.T.A.B. Feb.
`
`6, 2018) (“Patent Owner’s complaint about the multiple [IPR] petitions filed against
`
`[its] patent is not persuasive when the volume appears to be a direct result of its own
`
`litigation activity.”)
`
`V. CONCLUSION
`For all of the foregoing reasons, Petitioner eBay respectfully requests that the
`
`Board grant eBay’s Petition for Inter Partes Review of U.S. Patent No. 5,995,102
`
`and grant joinder with the proceeding pending in Amazon.com, Inc. v. Lexos Media
`
`IP, LLC, IPR2023-01000.
`
`
`
`
`
`Dated: December 20, 2023
`
`
`
`
`
`
`
`Respectfully submitted,
`
`_/Heath Briggs/_____
`Heath J. Briggs, Reg. No. 54,919
`GREENBERG TRAURIG, LLP
`1144 15th Street, Suite 3300
`Denver, CO 80202
`
`Joshua L. Raskin, Reg. No. 40,135
`Brian J. Prew, Reg. No. 76,717
`Vimal M. Kapadia, Reg. No. 73,310
`Kathryn E. Albanese, Reg. No. 78,153
`Greenberg Traurig, LLP
`One Vanderbilt Avenue
`New York, NY 10017
`
`Counsel for Petitioner eBay, Inc.
`
`
`13
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that a true and correct copy of the Motion for
`
`Joinder has been served on the Patent Owner via United States Postal Service
`
`(USPS) Priority Express Mail, or by means at least as fast and reliable USPS Priority
`
`Express Mail, on December 20, 2023, at the following address:
`
`
`
`
`
`WEINGARTEN SCHURGIN GAGNEBIN & HAYES LLP
`TEN POST OFFICE SQUARE
`BOSTON, MA 02109
`
`
`Dated: December 20, 2023
`
`
`
`
`
`Respectfully submitted,
`
`_/Heath Briggs/_____
`Heath J. Briggs, Reg. No. 54,919
`GREENBERG TRAURIG, LLP
`1144 15th Street, Suite 3300
`Denver, CO 80202
`
`Joshua L. Raskin, Reg. No. 40,135
`Brian J. Prew, Reg. No. 76,717
`Vimal M. Kapadia, Reg. No. 73,310
`Kathryn E. Albanese, Reg. No. 78,153
`Greenberg Traurig, LLP
`One Vanderbilt Avenue
`New York, NY 10017
`
`Counsel for Petitioner eBay, Inc.
`
`
`14
`
`
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