Case 6:21-cv-00569-ADA Document 241 Filed 07/21/23 Page 1 of 17
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`TOUCHSTREAM TECHNOLOGIES, INC.,
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`GOOGLE LLC,
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`GOOGLE LLC’S RULE 50(a) MOTION FOR JUDGMENT AS A MATTER OF LAW
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`Civil Case No. 6:21-cv-569-ADA
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`JURY TRIAL DEMANDED
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`§§§§§§§§§§
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`Plaintiff,
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`v.
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`Defendant.
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`Case 6:21-cv-00569-ADA Document 241 Filed 07/21/23 Page 2 of 17
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`TABLE OF CONTENTS
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`Page
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`GOOGLE IS ENTITLED TO JMOL ON TOUCHSTREAM’S INFRINGEMENT
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`INTRODUCTION ............................................................................................................. 1
`LEGAL STANDARD ........................................................................................................ 1
`ISSUES .............................................................................................................................. 2
`The Court Granted JMOL Of No Willful Infringement ........................................ 2
`Touchstream Withdrew Its DOE Theory Of Infringement .................................... 2
`Google Is Entitled To JMOL Of No Divided Infringement .................................. 2
`Products Do Not Have A “Server System” ............................................................ 5
`Limitations Are Met ............................................................................................... 5
`IV. GOOGLE IS ENTITLED TO JMOL ON THE PRIORITY DISPUTE ............................ 7
`GOOGLE IS ENTITLED TO JMOL OF INVALIDITY ................................................ 10
`CONCLUSION ................................................................................................................ 13
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`I.
`II.
`III.
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`V.
`VI.
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`A.
`B.
`C.
`D.
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`E.
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`Google Is Entitled To JMOL Of No Infringement Because The Accused
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`Google Is Entitled To JMOL Of No Infringement Because Not All Claim
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`-i-
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`Case 6:21-cv-00569-ADA Document 241 Filed 07/21/23 Page 3 of 17
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`Abbreviation
`Touchstream
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`Google
`asserted patents
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`asserted claims
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`GTS
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`Muthukumarasamy
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`TABLE OF ABBREVIATIONS
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`Definition
`Touchstream Technologies, Inc.
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`Google LLC
`U.S. Patent Nos. 8,356,251 (the “ʼ251 Patent”), 8,782,528 (the
`“ʼ528 Patent”), and 8,904,289 (the “ʼ289 Patent”)
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`Claims 1 and 8 of the ʼ251 Patent, claims 1 and 14 of the ʼ528
`Patent, and claims 1 and 2 of the ʼ289 Patent
`YouTube Remote and Leanback with Google TV System
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`U.S. Patent Application Publication No. 2010/0241699
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`*All emphasis added unless otherwise noted.
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`Case 6:21-cv-00569-ADA Document 241 Filed 07/21/23 Page 4 of 17
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`INTRODUCTION
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`I.
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`After Touchstream rested its case on July 19, 2023, Google orally moved for judgment as
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`a matter of law (“JMOL”) on each issue on which Touchstream bears the burden. Google moved
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`for JMOL of: no willful infringement, no infringement under the doctrine of equivalents
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`(‘DOE”), no divided infringement, no infringement because the accused products do not perform
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`or have all claim limitations, and no infringement because the accused products do not have a
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`“server system.” When Google renewed its motion for no willful infringement on July 20, 2023,
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`the Court granted the motion.
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`In addition, Google orally moved for JMOL of invalidity and that Touchstream failed to
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`carry its burden with regard to its alleged priority date and therefore all of Google’s asserted art
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`is prior art to the asserted patents. Google also renewed all of its prior motions.
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`As indicated in Court, Google hereby submits a brief written submission on its motions.
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`Google also memorializes the issues on which the Court has ruled to date. As explained here and
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`in Court, JMOL of the open issues of non-infringement, including no divided infringement,
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`should be granted, as well as JMOL that the patents are entitled only to the earliest filing date of
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`the patents (April 21, 2011) and that all of the asserted claims are invalid.
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`II.
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`LEGAL STANDARD
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`The Court may grant JMOL under Rule 50(a) “[i]f a party has been fully heard on an
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`issue during a jury trial and the court finds that a reasonable jury would not have a legally
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`sufficient evidentiary basis to find for the party on that issue.” Fed. R. Civ. P. 50(a). As a result,
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`JMOL is warranted “[i]f … the facts and inferences point so strongly and overwhelmingly in
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`favor of one party that the Court believes that [a] reasonable [jury] could not arrive at a contrary
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`verdict.” Med. Care Am., Inc. v. Nat’l Union Fire Ins. Co., 341 F.3d 415, 420 (5th Cir. 2003).
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`Case 6:21-cv-00569-ADA Document 241 Filed 07/21/23 Page 5 of 17
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`III. GOOGLE IS ENTITLED TO JMOL ON TOUCHSTREAM’S INFRINGEMENT
`ISSUES
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`Google seeks JMOL on all infringement issues in the case. Touchstream bears the
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`burden of proof on all infringement issues.
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`A.
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`The Court Granted JMOL Of No Willful Infringement
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`The Court granted Google’s motion for JMOL of no willful infringement. See
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`Tr. 1195:1-3.
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`As the record reflects, Touchstream failed to show that Google had knowledge of the
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`patents-in-suit (or was willfully blind to them), or had any specific intent to infringe (or was
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`willfully blind to infringement). See Tr. 702:2-703:13, 1171:20-1194:25. Touchstream likewise
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`failed to show that any of the factors generally considered in a willfulness assessment favored a
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`willfulness finding. See id.
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`As noted, the Court granted JMOL of no willfulness.
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`B.
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`Touchstream Withdrew Its DOE Theory Of Infringement
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`In response to Google’s motion for JMOL of no infringement under the doctrine of
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`equivalents (“DOE”), Touchstream stated that it withdrew its DOE theory. Tr. 701:22-25.
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`Accordingly, DOE is no longer an issue in this case.
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`C.
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`Google Is Entitled To JMOL Of No Divided Infringement
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`Google is entitled to JMOL of no divided infringement. Google acknowledges that the
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`Court denied Google’s oral motion, see Tr. 706:4-5, and respectfully summarizes here briefly the
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`grounds on which no reasonable jury could find Google liable for divided infringement of the
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`asserted claims.
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`-2-
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`Case 6:21-cv-00569-ADA Document 241 Filed 07/21/23 Page 6 of 17
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`All of the asserted claims are method claims, requiring the claimed steps to be performed
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`in order for there to be infringement. No reasonable jury could find Google is responsible for all
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`of the claim steps.
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`“Direct infringement under § 271(a) occurs where all steps of a claimed method are
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`performed by or attributable to a single entity.” Akamai Techs., Inc. v. Limelight Networks, Inc.,
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`797 F.3d 1020, 1022 (Fed. Cir. 2015) (en banc). A defendant can be held “responsible for
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`others’ performance of method steps in two sets of circumstances: (1) where that entity directs or
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`controls others’ performance, and (2) where the actors form a joint enterprise.” Id. No
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`reasonable jury could find Touchstream carried its burden on this test.
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`Touchstream presented no evidence of a joint enterprise, and no evidence of direction or
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`control. As a result, for multiple reasons, no reasonable jury could find Google responsible for
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`others’ performance of claims steps.
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`As one example, all asserted claims require action performed by a user—all claims
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`require a “personal computing device.” But Touchstream presented no evidence that Google
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`controls users or their “personal computing devices.” In fact, Touchstream’s expert
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`Dr. Almeroth admitted that users have to send these commands, such as pressing play or pause.
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`For example, he explained that “when [he] was using the dongle on my phone, I could hit play
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`and pause, and those messages would be sent and acted on by the dongle.” Tr. 440:16-22.
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`Because a user must perform an action required by the claims, Touchstream cannot meet its
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`burden to prove divided infringement.
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`As another example, all asserted claims, with their many claim limitations, require
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`specific commands, such as an “action control command” (’289 patent claim 1; ’528 patent
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`claim 1) or “universal playback control command” (’251 patent claim 1) from the claimed
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`-3-
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`Case 6:21-cv-00569-ADA Document 241 Filed 07/21/23 Page 7 of 17
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`“personal computing device.” Touchstream, however, presented no evidence that Google
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`controls such commands. Dr. Almeroth explained that an “action control command” “is kind of
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`a technical way of pause, rewind, fast forward, or stop,” and that this information “has to be
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`received in the server system.” Tr. 402:9-13; see also Tr. 415:12-15. Despite this claim
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`requirement, Dr. Almeroth emphasized that user input is required for those specific commands to
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`be sent. E.g., Tr. 440:10-22.
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`As another example, all asserted claims require applications from third-party providers,
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`e.g., Spotify and Netflix. But Touchstream presented no evidence that Google controls the
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`supplying of these applications and software. See, e.g., 502:1-503:4; 504. Nor, as noted above,
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`did Touchstream present evidence of a joint enterprise between Google and such providers.
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`Touchstream referenced YouTube, which Google owns, Tr. 609:19-20, but Touchstream
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`presented no evidence to support piercing the corporate veil or other form of direction or control
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`to meet its burden on divided infringement.
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`At minimum, Touchstream failed to prove direction and control for one of the categories
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`of accused products: “cast-enabled devices” that are made and sold by other entities, i.e., the
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`accused devices that implement Chromecast built-in. Given the absence of evidence that these
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`third parties are under Google’s direction or control, there can be no infringement of these
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`devices.
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`Given these evidentiary failures, no reasonable jury could find Google responsible for
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`others’ performance of claim steps. As such, JMOL of no divided infringement—and therefore
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`JMOL of no infringement—should be granted as to all accused products for all asserted claims.
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`-4-
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`Case 6:21-cv-00569-ADA Document 241 Filed 07/21/23 Page 8 of 17
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`D.
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`Google Is Entitled To JMOL Of No Infringement Because The Accused
`Products Do Not Have A “Server System”
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`Touchstream failed to show the accused products have a “server system” that performs
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`all of the claimed requirements—a key element of each of the asserted claims. All asserted
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`claims require performance of particular operations by the “server system.” And all asserted
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`claims require that certain commands or information be sent to or from the “server system.” No
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`reasonable jury could find that the accused products have a “server system” that can perform all
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`of the required operations. Touchstream’s theory depends on superficial labeling, e.g., that the
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`accused products have a “server,” failing to apply the plain and ordinary meaning of “server
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`system.” Touchstream’s infringement theory accuses distinct components used in the accused
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`products and other devices as somehow being the claimed “server system.” See, e.g., Tr. 430:5-
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`433:4. As a matter of law, that fails to carry its burden on infringement.
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`E.
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`Google Is Entitled To JMOL Of No Infringement Because Not All Claim
`Limitations Are Met
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`It is axiomatic that literal infringement requires each and every claim limitation is met.
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`When “no reasonable fact finder could determine that the accused devices meet every limitation
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`of the properly construed claims,” JMOL of no infringement is warranted. Power-One, Inc. v.
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`Artesyn Techs., Inc., No. 2:05-CV-463, 2008 WL 11348356, at *2 (E.D. Tex. Feb. 15, 2008)
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`(quoting Elkay Mfg. Co. v. Ebco Mfg. Co., 192 F.3d 973, 980 (Fed. Cir. 1999)). Touchstream
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`failed to offer sufficient evidence of literal infringement of each asserted claim. See, e.g., Tr.
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`380:3-533:21 (direct, cross, redirect, and recross examination of Touchstream’s technical
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`expert).
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`As an example, claims 1 and 2 of the ’289 patent and claims 1 and 14 of the ’528 patent
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`recite “receiving, in a server system, one or more messages from a personal computing device”
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`that “identify a location of the particular media player.” Touchstream contends that this
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`-5-
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`limitation is met by the Phone sending a Cast App ID to the Chromecast (or other cast-enabled
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`device) (“cast-enabled device”), which may ultimately download a receiver application (i.e., the
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`particular media player). However, Touchstream fails to meet its evidentiary burden that the
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`claimed “server system” receives messages that contain the Cast App ID because such messages
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`are received by the cast-enabled device, which is not part of the claimed server system. E.g., Tr.
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`928:7-929:20. Second, Touchstream’s reliance on the Cast App ID to identify a location of the
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`particular media player also fails. The accused receiver applications (i.e., the particular media
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`player) are web pages that are located by a Universal Resource Locator (“URL”). By contrast,
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`the Cast App ID is merely a number, which does not identify a location. E.g., Tr. 964:12-965:12.
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`As another, claims 1 and 8 of the ’251 patent recite “storing, in a database associated with
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`the server system, information for transmission to or retrieval by the display device, wherein the
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`information specifies the video file to be acted upon, identifies the particular media player for
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`playing the video content, and includes the corresponding programming code to control playing
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`of the video content on the display device by the particular media player in accordance with the
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`universal playback control command.” Touchstream contends that memory on the phone that
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`purportedly stores certain information meets this limitation. However, Touchstream fails to meet
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`its evidentiary burden that the phone (1) includes a database associated with the server system;
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`(2) stores information that specifies the video file to be acted upon, identifies the particular
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`media player, and includes the corresponding programming code; and (3) stores such
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`information for transmission to or retrieval by the display device. First, Touchstream’s claim
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`fails because memory on a phone is not associated with the server system, but is instead
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`associated with the phone on which it resides. E.g., Tr. 961:5-963:7. Second, Touchstream fails
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`to meet its evidentiary burden to show that the accused memory stores programming code, and,
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`-6-
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`Case 6:21-cv-00569-ADA Document 241 Filed 07/21/23 Page 10 of 17
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`in fact, such programming code that is intended to be executed by the particular media player on
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`the display device is not stored on the phone. E.g., id. Third, Touchstream fails to meet its
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`evidentiary burden that the claimed information is stored for transmission to or retrieval by the
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`display device, and, in fact, such information is not so transmitted or received. Rather, the
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`claimed functionality accused by Touchstream merely stores a “session identifier” that is used to
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`re-establish the peer-to-peer connection to the cast-enabled device. E.g., id.
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`Touchstream’s failure to show that each and every limitation is met by the accused
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`products precludes infringement as a matter of law.
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`IV. GOOGLE IS ENTITLED TO JMOL ON THE PRIORITY DISPUTE
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`In an attempt to predate certain of Google’s asserted prior art (regarding the GTS system
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`and specifically the YouTube Remote aspects of it), Touchstream claims October 8, 2010, as the
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`conception date of the asserted patents. No reasonable jury could find that Touchstream carried
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`its burden with respect to this issue. Accordingly, Touchstream is not entitled to its claimed
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`priority date (or a priority date before November 9, 2010), and instead the patents are governed
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`by their earliest filing date of April 21, 2011. Therefore, the whole of the GTS system including
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`its YouTube Remote aspects are prior art, and all of Google’s asserted art is prior art to the
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`asserted patents.
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`While Google bears the ultimate burden of proof on invalidity, Touchstream bears a
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`meaningful burden to be entitled to its claimed priority date. See Dynamic Drinkware, LLC v.
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`Nat’l Graphics, Inc., 800 F.3d 1375, 1379-80 (Fed. Cir. 2015) (to pre-date prior art, the patentee
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`bears burden of production on conception and reduction to practice).
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`Conception is “the formation in the mind of the inventor, of a definite and permanent idea
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`of the complete and operative invention, as it is hereafter to be applied in practice.” Burroughs
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`Wellcome Co. v. Barr Labs., Inc., 40 F.3d 1223, 1228 (Fed. Cir. 1994). As “a mental act,”
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`-7-
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`Case 6:21-cv-00569-ADA Document 241 Filed 07/21/23 Page 11 of 17
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`conception requires contemporaneous “corroborating evidence” “that would enable one skilled in
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`the art to make the invention.” Burroughs, 40 F.3d at 1228; see also Brown v. Barbacid, 276
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`F.3d 1327, 1335 (Fed. Cir. 2002) (“A party seeking to prove conception via the oral testimony of
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`a putative inventor must proffer evidence corroborating that testimony.”) “Conception must
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`include every feature or limitation of the claimed invention.” Kridl v. McCormick, 105 F.3d
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`1446, 1449 (Fed. Cir. 1997).
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`Touchstream failed to carry its burden regarding its claimed priority date.
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`Mr. Strober’s claimed conception of the asserted claims is not supported by sufficient
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`evidence, nor adequately corroborated, for a jury to find for Touchstream on this issue. See Tr.
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`85:22-88, 89:20-24. The only documentary evidence Touchstream introduced were five source
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`code snippets and a schematic. JTX-218, JTX-226, JTX-228, JTX-254, JTX-255, DTX-637.
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`But metadata from the documents does not provide corroboration—many had “last-modified
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`date” post-dating October 2010. See Transocean Offshore Deepwater Drilling, Inc. v.
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`GlobalSantaFe Corp., 443 F. Supp. 2d 836, 856 (S.D. Tex. 2006) (inventor’s testimony that he
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`made electronic drawings before “last modified date” of drawings insufficient to corroborate
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`conception date). And Mr. Strober was in control of the documents, and there is no evidence he
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`showed them to anyone else. EMC Corp. v. Pure Storage, Inc., 204 F. Supp. 3d 749 (D. Del.
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`2016) (granting JMOL on this basis).
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`Touchstream presented testimony from Mr. Mitschele and Mr. Rinzler that they
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`witnessed the prototype when they met Mr. Strober in New York in 2011, but that was well past
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`the alleged October 2010 conception date. Tr. 184:8-185:17, 252:15-253:19.
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`There is also no evidence of conception and reduction to practice of each and every claim
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`element. See Kridl, 105 F.3d at 1449 (“Conception must include every feature or limitation of
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`-8-
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`Case 6:21-cv-00569-ADA Document 241 Filed 07/21/23 Page 12 of 17
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`the claimed invention.”); Slip Track Sys., Inc. v. Metal-Lite, Inc., 304 F.3d 1256, 1265 (Fed. Cir.
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`2002) (“actual reduction to practice” requires “an embodiment or perform[ing] a process that met
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`all the limitations of the claims”).
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`As Dr. Mayer-Patel testified, there is no record evidence of the claimed “synchronization
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`code,” “stor[ing]in the server system a record establishing the association,” “signals identifying
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`the particular media player,” “converting of the universal playback controls into programming
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`code which was then transmitted to the display device.” Tr. 1015:2-24. Dr. Mayer-Patel’s
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`overview of the elements missing from Mr. Strober’s purported prototype are summarized in the
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`following demonstrative he discussed before the jury.1
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`Touchstream’s failure to produce evidence of a prototype, much less one that reduced the
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`asserted claims to practice, precludes its claimed priority date. See Tr. 115:5-12 (Mr. Strober
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`1 Google notes that the trial demonstratives are not evidence, but provides them for the
`Court’s convenience.
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`-9-
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`Case 6:21-cv-00569-ADA Document 241 Filed 07/21/23 Page 13 of 17
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`admitting that no prototype was presented at trial); see also Tr. 1016:25-1017:5 (Dr. Mayer-
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`Patel: “we haven’t seen that prototype”).
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`And, while Dr. Almeroth promised the jury he would revisit this issue during his rebuttal
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`case, neither he nor Touchstream provided any further evidence that could support its claimed
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`priority date.
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`JMOL on this issue should be granted to Google.
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`V.
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`GOOGLE IS ENTITLED TO JMOL OF INVALIDITY
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`Google is entitled to invalidity of all asserted claims. As the trial record reflects, the
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`asserted claims of the ’251 patent are invalid as obvious over GTS, the asserted claims of the
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`’528 patent are invalid as obvious over the combination of GTS and Muthukumarasamy, and the
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`asserted claims of the ’289 patent are likewise invalid as obvious over the combination of GTS
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`and Muthukumarasamy.
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`Claims 1 and 8 of the ’251 Patent. Google is entitled to JMOL of obviousness for each
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`of Touchstream’s asserted claims. Google presented clear and convincing evidence that the
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`asserted claims of the ’251 patent (claims 1 and 8) are invalid as obvious. Dr. Mayer-Patel
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`provided a detailed, element-by-element analysis of how GTS discloses and renders obvious the
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`claims of the ’251 patent under 35 U.S.C. § 103. Tr. 967:9-15, 980:22-997:12 (independent
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`claim 1); 997:24-999:7 (dependent claim 8), 999:8-12 (all asserted claims rendered obvious).
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`The claim chart that Dr. Mayer-Patel discussed in detail before the jury illustrates that each claim
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`limitation is met.
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`-10-
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`Case 6:21-cv-00569-ADA Document 241 Filed 07/21/23 Page 14 of 17
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`Claims 1 and 14 of the ’528 Patent. Google similarly presented clear and convincing
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`evidence that the asserted claims of the ’528 patent (claims 1 and 14) are invalid. Dr. Mayer-
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`Patel provided a detailed, element-by-element analysis of how the combination of GTS and
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`Muthukumarasamy discloses and renders obvious the claims of the ’528 patent under § 103. Tr.
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`967:16-21, 999:19-1008:19 (independent claim 1), 1008:20-1009:21 (dependent claim 14),
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`1009:22-24 (all asserted claims obvious). The claim charts that Dr. Mayer-Patel discussed in
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`detail before the jury illustrates that each claim limitation is met.
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`-11-
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`Case 6:21-cv-00569-ADA Document 241 Filed 07/21/23 Page 15 of 17
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`Claims 1 and 2 of the ’289 Patent. Google further presented clear and convincing
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`evidence that the asserted claims of the ’289 patent (claims 1 and 2) are invalid as obvious.
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`Dr. Mayer-Patel provided a detailed, element-by-element analysis of how the combination of
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`GTS and Muthukumarasamy discloses and renders obvious the claims of the ’251 patent under
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`§ 103. Tr. 967:16-21, 1009:25-1011:22 (independent claim 1), 1011:23-1012:14 (dependent
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`claim 2), 1012:15-22 (all asserted claims obvious). The claim chart that Dr. Mayer-Patel
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`discussed in detail before the jury illustrates that each claim limitation is met.
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`-12-
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`Case 6:21-cv-00569-ADA Document 241 Filed 07/21/23 Page 16 of 17
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`In response to Google’s showing that each asserted claim is invalid, Touchstream
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`presented no contrary evidence a reasonable jury could credit, nor any evidence of secondary
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`considerations of non-obviousness.
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`VI. CONCLUSION
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`For the reasons stated above and in Court, Google respectfully moves for JMOL of no
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`infringement, including no divided infringement, of any asserted claim of the asserted patents,
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`for JMOL that the priority date of the asserted patents is not October 8, 2010 (and instead is
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`April 21, 2011), and for JMOL that each asserted claim of the asserted patents is invalid.
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`The Court granted JMOL of no willful infringement, and Touchstream has withdrawn its
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`DOE theory of infringement.2
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`2 Orally in Court after Touchstream rested, Google also moved for no permanent
`injunction. Consistent with the Court’s preferences, Google will address that issue later, if and
`when necessary.
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`-13-
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`Case 6:21-cv-00569-ADA Document 241 Filed 07/21/23 Page 17 of 17
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`Dated: July 21, 2023
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`Respectfully submitted,
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`By: /s/ Tharan Gregory Lanier with permission,
`by Michael E. Jones
`Michael C. Hendershot (admitted Pro Hac Vice)
`Tharan Gregory Lanier (admitted Pro Hac Vice)
`Evan M. McLean (admitted Pro Hac Vice)
`Gurneet Singh (admitted Pro Hac Vice)
`JONES DAY
`1755 Embarcadero Road
`Palo Alto, CA 94303
`(650) 739-3939
`Fax: (650) 739-3900
`mhendershot@jonesday.com
`tglanier@jonesday.com
`emclean@jonesday.com
`gsingh@jonesday.com
`
`Tracy Ann Stitt (admitted Pro Hac Vice)
`Jennifer L. Swize (admitted Pro Hac Vice)
`Edwin O. Garcia (admitted Pro Hac Vice)
`John R. Boulé III (admitted Pro Hac Vice)
`JONES DAY
`51 Louisiana NW
`Washington, DC 20001
`(202) 879-3939
`Fax: (202) 626-1700
`tastitt@jonesday.com
`jswize@jonesday.com
`edwingarcia@jonesday.com
`jboule@jonesday.com
`
`Michael E. Jones
`TX State Bar No. 10929400
`E-mail: mikejones@potterminton.com
`Shaun W. Hassett
`TX State Bar No. 24074372
`E-mail: shaunhassett@potterminton.com
`POTTER MINTON PC
`102 N. College Ave., Suite 900
`Tyler, TX 75702
`Telephone: (903) 597-8311
`Facsimile: (903) 593-0846
`
`Attorneys for Defendant Google LLC
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`-14-
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