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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
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`CHARTER COMMUNICATIONS, INC.,
`Petitioner
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`v.
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`TOUCHSTREAM TECHNOLOGIES, INC.
`Patent Owner
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`____________
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`Case No. IPR2024-01232
`U.S. Patent No. 11,048,751
`____________
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`PETITIONER’S MOTION FOR JOINDER
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`IPR2024-01232
`U.S. Patent No. 11,048,751
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`TABLE OF CONTENTS
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`I. STATEMENT OF RELIEF REQUESTED ........................................................ 1
`II. BACKGROUND ................................................................................................. 2
`III. LEGAL STANDARD ..................................................................................... 3
`IV. STATEMENT OF REASONS FOR RELIEF REQUESTED ........................ 5
`A. Petitioner’s Motion for Joinder is Timely ....................................................... 5
`B. The Board Should Permit Joinder ................................................................... 5
`1. Joinder is Appropriate for Several Reasons ................................................. 6
`2. Petitioner Proposes No New Grounds of Unpatentability ........................... 7
`3. Joinder Will Not Unduly Burden or Negatively Impact the Comcast IPR
`Trial Schedule .................................................................................................... 7
`4. How Briefing and Discovery May Be Simplified ........................................ 7
`V. GENERAL PLASTIC IS INAPPLICABLE ....................................................... 9
`VI. CONCLUSION ................................................................................................11
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`TABLE OF AUTHORITIES
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`Cases
`Celltrion, Inc. v. Genentech, Inc.,
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`IPR2018-01019 (PTAB Oct. 30, 2018) ................................................................. 9
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`Central Security Grp. — Nationwide, Inc. v. Ubiquitous Connectivity, LP,
`IPR2019-01609 (PTAB Feb. 26, 2020) .............................................................6, 9
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`Click-To-Call Techs., LP v. Ingenio, Inc., YellowPages.com, LLC,
` 899 F.3d 1321 (Fed. Cir. 2018) ............................................................................. 4
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`Dell Inc. v. Network-1 Sec. Sols., Inc.,
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`IPR2013-00385 (PTAB July 29, 2013) ................................................................. 4
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`Facebook, Inc. v. Windy City Innov., LLC,
` 973 F.3d 1321 (Fed. Cir. 2020) .........................................................................3, 4
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`General Plastic Indus. Co. v. Canon Kabushiki Kaisha,
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`IPR2016-01357 (PTAB Sept. 6, 2017) .................................................................. 9
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`Hyundai Motor Co. v. Am. Vehicular Sci. LLC,
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`IPR2014-01543 (PTAB Oct. 24, 2014) ................................................................. 4
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`Intel Corp. v. VLSI Techn. LLC,
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`IPR2022-00479 (PTAB June 6, 2022) ...............................................................3, 5
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`Kingston Tech. Co., Inc. v. Securewave Storage Sols., Inc.,
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`IPR2020-00139 (PTAB Mar. 23, 2020) ............................................................4, 5
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`Kyocera Corp. v. Softview LLC,
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`IPR2013-00004 (PTAB April 24, 2013)....................................................... 3, 4, 6
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`Macronix Int’l Co. v. Spansion,
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`IPR2014-00898 (PTAB Aug. 13, 2014) ................................................................ 4
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`Mercedes-Benz USA, LLC v. Carucel Invs. L.P.,
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`IPR2019-01404 (PTAB Jan. 22, 2020) ................................................................10
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`ii
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`IPR2024-01232
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`Mylan Pharms. Inc. v. Novartis AG,
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`IPR2015-00268 (PTAB April 10, 2015)................................................................ 8
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`NetNut Ltd. v. Bright Data Ltd.,
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`IPR2021-00465 (PTAB Aug. 12, 2021) ..............................................................10
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`Sony Corp. v. Memory Integrity, LLC,
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`IPR2015-01353 (PTAB Oct. 5, 2015) ...............................................................7, 8
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`Thryv v. Click-to-Call Techs., LP,
` 590 U.S. 45, 60 (2020) ........................................................................................... 3
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`Toshiba Am. Info. Sys., Inc. v. Walletex Microelecs. Ltd.,
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`IPR2018-01538 (PTAB Mar. 5, 2019) ................................................................10
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`Statutes
`35 U.S.C. § 315 ......................................................................................................3, 4
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`Rules
`37 C.F.R. § 42.122 .................................................................................................1, 5
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`iii
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`IPR2024-01232
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`I.
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`STATEMENT OF RELIEF REQUESTED
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`Pursuant to 35 U.S.C. § 315(c) and 37 C.F.R. § 42.122(b), Charter
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`Communications, Inc. (“Petitioner”) respectfully moves for joinder with the Inter
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`Partes Review instituted in Comcast Cable Communications, LLC v. Touchstream
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`Technologies, Inc., IPR2024-00324, instituted on July 24, 2024 (“the Comcast IPR”),
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`for U.S. Patent No. 11,048,751 (“the ’751 patent”). See IPR2024-00324, Paper 13.
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`This motion is timely because it is filed “no later than one month after the
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`institution date of any inter partes review for which joinder is requested.” 37 C.F.R.
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`§ 42.122(b).
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` Petitioner has consulted with counsel for Comcast Cable
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`Communications, LLC (“Comcast”), and Comcast does not oppose Petitioner’s
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`request.
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`The grounds in the instant Petition—and evidence upon which they rely—are
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`identical to the grounds in the Comcast IPR, which the Board instituted. Further, if
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`joined, Petitioner will assume a “silent understudy” role and will actively participate
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`substantively in the Comcast IPR only if Comcast terminates its involvement after
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`joinder. Thus, the proposed joinder will not complicate or delay the Comcast IPR
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`in any manner, or prejudice the Patent Owner. Accordingly, Petitioner respectfully
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`requests that the Board institute Petitioner’s IPR and grant this Motion for Joinder.
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`IPR2024-01232
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`II. BACKGROUND
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`On February 16, 2023, Patent Owner filed suit against Charter
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`Communications, Inc., Charter Communications Operating, LLC, Time Warner
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`Cable Enterprises LLC, Spectrum Management Holding Company, LLC, Spectrum
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`Gulf Coast, LLC, and Charter Communications, LLC, asserting related U.S. Patent
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`No. 8,356,251 (“the ’251 patent”). Touchstream Techs., Inc. v. Charter Commc’ns,
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`Inc. et al, 2-23-cv-00059-RJG (E.D. Tex.). The ’751 patent and related U.S. Patent
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`No. 11,086,934 (“the ’934 patent”) were added in a first amended complaint filed
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`on May 25, 2023.
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`Patent Owner filed suit against Comcast, Comcast Corp., Comcast Cable
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`Communications Management, LLC, and Comcast of Houston, LLC on February
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`17, 2023, asserting the ’251 patent. Touchstream Techs., Inc. v. Comcast Cable
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`Commc’ns, LLC et al, 2-23-cv-00062-RJG (E.D. Tex.). On that same day, Patent
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`Owner filed suit against Altice USA, Inc., Cequel Communications, LLC, CSC
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`Holdings, LLC, and Friendship Cable of Texas, Inc., asserting the ’251 patent.
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`Touchstream Techs., Inc. v. Altice USA, Inc. et al, 2-23-cv-00060-RJG (E.D. Tex.).
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`The ’751 patent and the ’934 patent were also asserted against the Comcast entities
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`and the Altice entities in first amended complaints.
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`On December 27, 2023, Comcast filed IPR2024-00324 for IPR of the ‘751
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`patent. Comcast Cable Commc’ns, LLC v. Touchstream Techs., Inc., IPR2024-
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`IPR2024-01232
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`00324, Paper 2 (PTAB Dec. 27, 2023). On July 24, 2024, the Board instituted the
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`Comcast IPR. IPR2024-00324, Paper 13. The instant Petition is the same as the
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`Comcast IPR: it involves the same patent, claims, grounds of unpatentability, and
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`evidence.
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`III. LEGAL STANDARD
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`The Board has the authority to join Petitioner as a party to the Comcast IPR.
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`35 U.S.C. § 315(c); see also 35 U.S.C. § 315(d) (The Board also has the authority to
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`consolidate proceedings.). Whether a request for joinder should be granted is
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`discretionary. Kyocera Corp. v. Softview LLC, IPR2013-00004, Paper 15 at 4
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`(PTAB April 24, 2013).
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`“In deciding whether to join a party to an inter partes review, § 315(c) requires
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`‘two different decisions,’ first ‘whether the joinder applicant’s petition for IPR
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`warrants institution under § 314,’ and then whether to ‘exercise . . . discretion to
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`decide whether to join as a party the joinder applicant.’ See Facebook, Inc. v. Windy
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`City Innov., LLC, 973 F.3d 1321, 1332 (Fed. Cir. 2020). ‘The statute makes clear
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`that the joinder decision is made after a determination that a petition warrants
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`institution, thereby affecting the manner in which an IPR will proceed.’ Id. (citing
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`Thryv v. Click-to-Call Techs., LP, 590 U.S. 45, 60 (2020)).” Intel Corp. v. VLSI
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`Techn. LLC, IPR2022-00479, Paper 13 at 4 (PTAB June 6, 2022).
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`“A motion for joinder should: (1) set forth the reasons joinder is appropriate;
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`(2) identify any new grounds of unpatentability asserted in the petition; (3) explain
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`what impact (if any) joinder would have on the trial schedule for the existing review;
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`and (4) address[] specifically how briefing and discovery may be simplified.”
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`Kingston Tech. Co., Inc. v. Securewave Storage Sols., Inc., IPR2020-00139, Paper
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`12 at 6–7 (PTAB Mar. 23, 2020); see, e.g., Hyundai Motor Co. v. Am. Vehicular Sci.
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`LLC, IPR2014-01543, Paper 11 at 3 (PTAB Oct. 24, 2014); Macronix Int’l Co. v.
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`Spansion, IPR2014-00898, Paper 15 at 4 (PTAB Aug. 13, 2014); Dell Inc. v.
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`Network-1 Sec. Sols., Inc., IPR2013-00385, Paper 17 (PTAB July 29, 2013);
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`Kyocera Corp. v. Softview LLC, IPR2013-00004, Paper 15 at 4 (PTAB April 24,
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`2013)).
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`Under § 315(b), entities who would otherwise be time-barred may file IPR
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`petitions with accompanying motions for joinder pursuant to § 315(c). The Federal
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`Circuit has recognized that “§ 315(b) includes a specific exception to the time bar.”
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`Facebook,
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`Inc., 973 F.3d at 1333
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`(quoting 35 U.S.C. § 315(b)).
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`“Congress . . . demonstrated that it knew how to provide an exception to the time bar
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`by including a second sentence in the provision: ‘The time limitation set forth in the
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`preceding sentence shall not apply to a request for joinder under subsection (c).’”
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`Click-To-Call Techs., LP v. Ingenio, Inc., YellowPages.com, LLC, 899 F.3d 1321,
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`1331 (Fed. Cir. 2018) (quoting 35 U.S.C. § 315(b)).
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`IV. STATEMENT OF REASONS FOR RELIEF REQUESTED
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`In view of the applicable law, the Board should exercise its discretion to grant
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`joinder and institute Petitioner’s copycat IPR on the ’751 patent joining it to the
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`Comcast IPR for the reasons set forth below under the Kingston framework.
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`A.
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`Petitioner’s Motion for Joinder is Timely
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`The Motion for Joinder and accompanying Petition are timely because they
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`are filed less than one month after the July 24, 2024 decision instituting trial in the
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`Comcast IPR. 37 C.F.R. § 42.122(b) (“Any request for joinder must be filed . . . no
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`later than one month after the institution date of any inter partes review for which
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`joinder is requested.”); see, e.g., Kingston Tech., IPR2020-00139, Paper 12 at 6–7
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`(holding that “me-too” petition was timely where it was filed more than one year
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`after petitioner was sued for infringement but within one month of the institution of
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`the IPR which petitioner sought to join); Intel, IPR2022-00479, Paper 13 at 17
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`(“Petitioner’s timeliness in filing the Petition and requesting joinder minimized the
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`potential disruption to an existing proceeding if joinder is granted . . . those aspects
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`of Petitioner’s approach support granting joinder.”).
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`B.
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`The Board Should Permit Joinder
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`In deciding whether to exercise its discretion and permit joinder, the Board
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`considers: (1) why joinder is appropriate; (2) whether the new petition presents any
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`new grounds of unpatentability; (3) any impact joinder would have on the trial
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`schedule for the existing review; and (4) how briefing and discovery may be
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`simplified. Kyocera Corp., IPR 2013-00004, Paper 15 at 4. Here, each of the four
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`factors weighs in favor of joinder.
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`Joinder is Appropriate for Several Reasons
`1.
`Joinder is appropriate here because the concurrently filed Petition involves the
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`same patent, challenges the same claims, relies on the same exhibits, and is based on
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`the same grounds and combinations of prior art submitted in the Comcast IPR. The
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`concurrently filed Petition is substantively identical to the Comcast IPR petition,
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`containing only minor differences relating to (a) the procedural formalities of having
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`a different Petitioner file the Petition, and (b) changes to arguments regarding
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`discretionary denial under § 314(a) that result from a different co-pending litigation.
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`There are no changes to the facts, citations, evidence, or arguments presented in the
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`grounds for unpatentability set forth in the Comcast IPR petition. Because the
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`proceedings are substantively identical, good cause exists for joining Petitioner as a
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`party to the Comcast IPR and consolidating the proceedings, so that the Board can
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`efficiently resolve identical challenges in a single proceeding. Central Security Grp.
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`— Nationwide, Inc. v. Ubiquitous Connectivity, LP, IPR2019-01609, Paper 11 at 8
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`(PTAB Feb. 26, 2020).
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`Petitioner Proposes No New Grounds of Unpatentability
`2.
`The concurrently filed Petition presents the same grounds of unpatentability
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`as the Comcast Petition and challenges the same claims. Therefore, Petitioner does
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`not propose any new grounds of unpatentability and this factor also favors joinder.
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`3.
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`Joinder Will Not Unduly Burden or Negatively Impact the
`Comcast IPR Trial Schedule
`Because Petitioner’s Petition is substantively identical to the Comcast
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`Petition—presenting the same grounds and challenging the same claims using the
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`same evidence—there are no new issues for Patent Owner to address. Further,
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`joinder with the Comcast IPR will not unduly burden or negatively impact the
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`schedule in that proceeding in any way. Thus, this factor also favors joinder. Sony
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`Corp. v. Memory Integrity, LLC, IPR2015-01353, Paper 11 at 6 (PTAB Oct. 5, 2015)
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`(granting motion where joinder does “not necessitate any additional briefing or
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`discovery from Patent Owner beyond that already required [by the original IPR]”).
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`4. How Briefing and Discovery May Be Simplified
` The concurrently filed Petition and
`the Comcast Petition present
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`substantively identical grounds of unpatentability, including the same combinations
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`of art against the same claims. Additionally, if this motion for joinder is granted,
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`Petitioner agrees to take an “understudy” role, adhering to the following restrictions,
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`as described by the Board:
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`“(a) all filings by [Petitioner] in the joined proceeding be consolidated with
`[Comcast’s], unless a filing solely concerns issues that do not involve
`[Comcast]; (b) [Petitioner] shall not be permitted to raise any new grounds not
`already instituted by the Board in the [Comcast IPR], or introduce any
`argument or discovery not already introduced by [Comcast]; (c) [Petitioner]
`shall be bound by any agreement between [Patent Owner] and [Comcast]
`concerning discovery and/or depositions; and (d) [Petitioner] at deposition
`shall not receive any direct, cross-examination or redirect time beyond that
`permitted for [Comcast alone under either 37 C.F.R. § 42.53 or any agreement
`between [Patent Owner] and [Comcast].”
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`Mylan Pharms. Inc. v. Novartis AG, IPR2015-00268, Paper 17 at 5 (PTAB
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`April 10, 2015); Sony, IPR2015-01353, Paper 11 at 6 (granting joinder where
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`petitioners requested an “understudy” role). Petitioner will assume the primary role
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`only if Comcast ceases to participate in the Comcast IPR.
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`By joining Petitioner in the Comcast IPR and allowing Petitioner to take on
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`an understudy role, both briefing and discovery will be simplified because Patent
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`Owner can maintain its current trial schedule and avoid duplicative efforts. The
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`understudy role will minimize any potential complications or delay that potentially
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`could result by joinder, including duplicative discovery and filings. Sony, IPR2015-
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`01353, Paper 11 at 6–7 (“[J]oinder would increase efficiency by eliminating
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`duplicative filings and discovery, and would reduce costs and burdens on the par-
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`ties as well as the board” where petitioners sought an “understudy” role.). Thus, this
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`factor also favors joinder.
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`For these foregoing reasons, each of the factors that the Board considers in
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`evaluating potential joinder weighs in favor of granting this Motion.
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`V. GENERAL PLASTIC IS INAPPLICABLE
`The General Plastic analysis is inapplicable to this concurrently filed Petition.
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`In General Plastic, the Board set forth factors for analyzing follow-on petitions.
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`Generally, these factors are intended to help conserve the Board’s resources and to
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`prevent a subsequent petitioner from gaining a strategic advantage from filing a later
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`petition. General Plastic Indus. Co. v. Canon Kabushiki Kaisha, IPR2016-01357,
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`Paper 19 (PTAB Sept. 6, 2017).
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`Here, Petitioner is not filing a follow-on petition. Rather, Petitioner seeks to
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`join the Comcast IPR as an understudy and does not present any new grounds. This
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`is not the type of serial petition necessitating a General Plastic analysis. The Board
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`has found that the General Plastic factors are “not particularly relevant” in this
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`situation, i.e., where a different petitioner files a “me-too” or “copycat” petition with
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`a timely motion for joinder. Central Security Grp., IPR2019-01609, Paper 11 at 8;
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`Celltrion, Inc. v. Genentech, Inc., IPR2018-01019, Paper 11 at 9–11 (PTAB Oct. 30,
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`2018).
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`Even if the Board were to consider the General Plastic factors, they would
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`weigh in favor of institution. Petitioner has not previously filed a petition against
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`the ’751 patent. Petitioner and the prior petitioner are not the same party and have
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`no significant relationship. They are competitors accused of infringement based on
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`sales of different products. This weighs against denial. NetNut Ltd. v. Bright Data
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`Ltd., IPR2021-00465, Paper 11 at 9 (PTAB Aug. 12, 2021) (declining to extend
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`General Plastic and Valve to different petitioner with no relationship to previous
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`petitioners); Mercedes-Benz USA, LLC v. Carucel Invs. L.P., IPR2019-01404, Paper
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`12 at 11–12 (PTAB Jan. 22, 2020); Toshiba Am. Info. Sys., Inc. v. Walletex
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`Microelecs. Ltd., IPR2018-01538, Paper 11 at 20 (PTAB Mar. 5, 2019).
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`The second through fifth factors relate to timing issues that are largely
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`irrelevant. When Petitioner learned of the prior art, whether Petitioner received
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`Patent Owner’s preliminary response or an institution decision, and the length of
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`time between the filing of the petitions, are all irrelevant. Petitioner did not
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`previously file any IPR petition, has substantively duplicated the Comcast IPR,
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`alleging the same facts, grounds, and prior art, and has agreed to take an understudy
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`role. As a result, this IPR cannot be considered an attempt to harass Patent Owner
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`or otherwise engage in serial, tactical filings. Petitioner seeks to simplify and
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`minimize the number of distinct proceedings by joining the Comcast IPR rather than
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`pursuing a separate IPR based on different grounds.
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`The sixth factor considers the Board’s resources and the seventh factor relates
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`to the Board’s ability to meet the one-year statutory deadline. Allowing joinder here
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`would not impact the Board’s resources (beyond those dedicated to deciding this
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`Motion), and would not impact the Board’s ability to meet the one-year statutory
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`deadline.
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`For the foregoing reasons, the General Plastic factors do not weigh against
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`institution and joinder of Petitioner to the Comcast IPR.
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`VI. CONCLUSION
`Joinder will not affect the substance, procedure, or scheduling of the Comcast
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`proceeding but will simplify the issues and promote efficiency, justice, and speed.
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`For the foregoing reasons, Petitioner respectfully requests inter partes review of U.S.
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`Patent No. 11,048,751 and joinder with IPR2024-00324.
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`Dated: August 9, 2024
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`Respectfully submitted,
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`/s/ Jeffrey A. Miller
`Jeffrey A. Miller
`Lead Counsel (Reg. No. 35,287)
`Arnold & Porter Kaye Scholer LLP
`3000 El Camino Real
`Five Palo Alto Square, Suite 500
`Palo Alto, CA 94306-3807
`Telephone: 650.319.4500
`Facsimile: 650.319.4700
`jeffrey.miller@apks.com
`
`Elizabeth A. Long
`Backup Counsel (Reg. No. 51,966)
`Arnold & Porter Kaye Scholer LLP
`250 West 55th Street
`New York, New York 10019-9710
`Telephone: 212.836.8000
`Facsimile: 212.836.8689
`elizabeth.long@arnoldporter.com
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`CERTIFICATE OF SERVICE
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`I hereby certify that on August 9, 2024, I caused a true and correct copy of the
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`foregoing PETITIONER’S MOTION FOR JOINDER to be served via FedEx
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`Priority Overnight on the following:
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`SHOOK, HARDY & BACON LLP
`Touchstream Technologies (149550)
`INTELLECTUAL PROPERTY DEPARTMENT
`2555 Grand Blvd. Kansas City, MO 64108
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`Courtesy copies of the foregoing document were served by e-mail on the
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`following counsel of record for Touchstream Technologies, Inc., the Patent Owner,
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`in the Underlying Litigation:
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`Robert H. Reckers
`Anita Liu
`Andrew M. Long
`Shook Hardy & Bacon LLP
`JPMorgan Chase Tower
`600 Travis Street, Suite 3400
`Houston, TX 77002-2926
`Tel.: (703) 227-8008
`rreckers@shb.com
`aliu@shb.com
`amlong@shb.com
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`Philip Eckert
`Evan James Weidner
`Shook, Hardy & Bacon LLP
`2555 Grand Boulevard
`Kansas City, MO 64108
`Tel.: (816) 421-5547
`peckert@shb.com
`eweidner@shb.com
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`Ryan D. Dykal
`Jordan T. Bergsten
`Mark D. Schafer
`Boies Schiller Flexner, LLP
`1401 New York Avenue, NW
`Washington, DC 20005
`Tel.: (202) 274-1109
`rdykal@bsfllp.com
`jbergsten@bsfllp.com
`mschafer@bsfllp.com
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`
`Melissa Richards Smith
`Gillam & Smith, LLP
`303 South Washington Avenue
`Marshall, TX 75670
`Tel.: (903) 934-8450
`melissa@gillamsmithlaw.com
`
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`
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`13
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`IPR2024-01232
`U.S. Patent No. 11,048,751
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`Courtesy copies of the foregoing document were served by e-mail on the
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`following counsel of record for Touchstream Technologies, Inc., the Patent Owner
`
`in IPR2024-00322:
`
`Kyle E. Friesen
`Robert H. Reckers
`SHOOK, HARDY & BACON L.L.P.
`600 Travis Street, Suite 3400
`Houston, TX 77002
`
`Jason R. Mudd
`Ryan Dykal
`SHOOK, HARDY & BACON L.L.P.
`2555 Grand Blvd.
`Kansas City, MO 64108
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`
`
`August 9, 2024:
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`
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`ARNOLD & PORTER KAYE SCHOLER LLP
`
`/s/ Jeffrey A. Miller
`Jeffrey A. Miller
`Counsel for Petitioner,
`Charter Communications, Inc.
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`14
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