Case IPR2014-01142
`Patent 7,917,843
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`SAMSUNG ELECTRONICS CO., LTD.,
`SAMSUNG ELECTRONICS AMERICA, INC., and
`SAMSUNG TELECOMMUNICATIONS AMERICA, LLC,
`
`Petitioners,
`
`v.
`
`Arendi S.A.R.L.,
`
`Patent Owner
`____________
`
`Case IPR2014-01142
`Patent 7,917,843
`____________
`
`ARENDI’S OPPOSITION TO MOTION FOR JOINDER
`FILED BY SAMSUNG ELECTRONICS CO., LTD.,
`SAMSUNG ELECTRONICS AMERICA, INC., and
`SAMSUNG TELECOMMUNICATIONS AMERICA, LLC
`
`
`
`
`
`Patent 7,917,843
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`SAMSUNG ELECTRONICS CO., LTD.,
`SAMSUNG ELECTRONICS AMERICA, INC., and
`SAMSUNG TELECOMMUNICATIONS AMERICA, LLC,
`
`Petitioners,
`
`v.
`
`Arendi S.A.R.L.,
`
`Patent Owner
`____________
`
`Case IPR2014-01142
`Patent 7,917,843
`____________
`
`ARENDI’S OPPOSITION TO MOTION FOR JOINDER
`FILED BY SAMSUNG ELECTRONICS CO., LTD.,
`SAMSUNG ELECTRONICS AMERICA, INC., and
`SAMSUNG TELECOMMUNICATIONS AMERICA, LLC
`
`
`
`
`
`
`Case IPR2014-01142
`Patent 7,917,843
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`
`TABLE OF CONTENTS
`
`
`I. INTRODUCTION .............................................................................................. 1
`II. FACTUAL BACKGROUND ............................................................................ 1
`A. Samsung Seeks to Add its Inter Partes Review to the Apple IPR ................. 1
`III. GROUND FOR JOINDER ............................................................................... 3
`A. Joinder Would Introduce Subject Matter that Falls Outside the Scope of Inter
`Partes Review ............................................................................................... 5
`B. Joinder Would Effectively Introduce New Grounds into the Apple IPR ........ 7
`C. Joinder Would Prejudice Arendi ................................................................... 8
`D. Joinder Would Add Significant Complexity, Delay and Cost to the Apple
`IPR, Thereby Unduly Delaying Its Resolution .............................................. 8
`Joinder Would Introduce New Evidence .................................................... 8
`i.
`ii. Joinder Would Expand and Complicate Discovery .................................. 10
`iii. Joinder Would Disrupt the Schedule of the Apple IPR, Leading to Undue
`Delays in Reaching Final Decision .......................................................... 11
`iv. Samsung has Improperly Numbered the Exhibits for its IPR .................... 12
`IV. Conclusion ..................................................................................................... 13
`
`
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`i
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`Case IPR2014-01142
`Patent 7,917,843
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`TABLE OF AUTHORITIES
`
`Cases
`Arendi S.A.R.L. v. Samsung Electronics Co. Ltd., et al., Case No. 1:2012cv01598
`(D. Del.) .............................................................................................................. 1
`Arthrex, Inc. v. Bonutti Skeletal Innovations LLC, IPR2013-00632, Paper No. 23 . 4
`Dell Inc. v. Network-1 Security Solutions, Inc., IPR2013-00385, Paper No. 17 ...... 9
`Microsoft Corp. v. Proxyconn, Inc.,IPR2013-00109, Paper No. 15 .................... 3, 4
`Motorola Mobility LLC v. SoftView LLC, IPR2013-00256, Paper No. 10 ............... 9
`NetApp, Inc. v. PersonalWeb Technologies, LLC & Level 3 Communications, IPR
`2013-00319, Paper No. 15 ................................................................................... 3
`Statutes
`35 U.S.C. § 102 .................................................................................................. 5, 6
`35 U.S.C. § 103 .................................................................................................. 5, 6
`35 U.S.C. § 311(b) ................................................................................................. 5
`Regulations
`37 C.F.R. § 42.101(b) ............................................................................................. 4
`37 C.F.R. § 42.51(b) ............................................................................................. 10
`
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`Case IPR2014-01142
`Patent 7,917,843
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`I. INTRODUCTION
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`Patent Owner Arendi S.A.R.L. (“Arendi”) respectfully requests that the
`
`Board deny Petitioners Samsung Electronics Co., Ltd., Samsung Electronics
`
`America, Inc., and Samsung Telecommunications America, LLC’s (“Samsung”)
`
`motion requesting joinder of IPR2014-01142 (“Samsung IPR”) with IPR2014-
`
`00208 (“Apple IPR”). The Samsung IPR and the Apple IPR each concern U.S.
`
`Patent No. 7,917,843 (“the ’843 patent”).
`
`The Board should deny Samsung’s motion because joinder will incorporate
`
`subject matter that forms an improper basis for challenging a patent via inter partes
`
`review, require a burdensome amount of additional discovery and expert
`
`testimony, and prevent a timely conclusion of the Apple IPR.
`
`II. FACTUAL BACKGROUND
`
`A. Samsung Seeks to Add its Inter Partes Review to the Apple IPR
`
`On December 4, 2012, Arendi served a complaint against Samsung alleging
`
`that certain Samsung products infringe certain claims of the ’843 patent. See
`
`Ex.2001, Arendi S.A.R.L. v. Samsung Electronics Co. Ltd., et al., Case No.
`
`1:2012cv01598 (D. Del.).
`
`On December 2, 2013, Apple Inc., Google Inc., and Motorola Mobility LLC
`
`filed a request for inter partes review of the claims of the ’843 patent. With this
`
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`1
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`Patent 7,917,843
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`request, Apple submitted a Declaration of Dr. Daniel A. Menascé. At this time,
`
`Samsung did not take any actions against the ’843 patent.
`
`On June 11, 2014, the Board instituted an inter partes review solely on the
`
`ground of obviousness based on Pandit.
`
`On July 11, 2014, Samsung served Arendi with a petition requesting inter
`
`partes review challenging the ‘843 Patent. The petition was accompanied by
`
`Samsung’s motion for joinder with the Apple IPR. In support of its IPR, Samsung
`
`has submitted a substantial amount of new evidence to be examined and
`
`considered in its IPR. The petition includes a total of nine (9) exhibits, including
`
`the declaration and curriculum vitae of Dr. Paul Clark, an expert who was not used
`
`in the Apple IPR. Samsung hides new evidence inside the declaration of Clark.
`
`The declaration discusses unasserted and non-produced prior art including X
`
`Windows, Microsoft Mail and Microsoft Word 95 in an attempt to satisfy missing
`
`claim limitations of Pandit. An excerpt from Merriam-Webster’s Collegiate®
`
`Dictionary, Tenth Edition, 1999 is also included as a new exhibit.
`
`Given that Samsung filed its petition more than one year after it was served
`
`with a complaint alleging infringement of the ‘843 patent, denial of this motion
`
`will automatically require denial of its petition for an inter partes review. Should
`
`the Board find that the burdens imposed by the Samsung IPR are not sufficient to
`
`deny joinder at this time, it should consider Patent Owner’s Preliminary Response,
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`2
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`Patent 7,917,843
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`which will be filed by August 11, 2014 to demonstrate that Samsung’s petition
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`does not meet the reasonable likelihood of prevailing standard.
`
`
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`III. GROUND FOR JOINDER
`
`The Board has considered some or all of the following factors when
`
`deciding on joinder of IPR proceedings:
`
`1. Whether the new proceeding would add new evidence. 1
`
`2. Whether joinder would be discernibly prejudicial to a party. 2
`
`3. Whether joinder will unduly delay the resolution of the proceeding. 3
`
`4. Whether the exhibits in the proceedings are consistently numbered. 4
`
`All of these factors are present here. The Apple IPR and the Samsung IPR
`
`should not be joined, among other reasons, because the Samsung IPR petition
`
`1 See, for example, NetApp, Inc. v. PersonalWeb Technologies, LLC & Level 3
`
`Communications, IPR 2013-00319, Paper No. 15.
`
`2 See, for example, Microsoft Corp. v. Proxyconn, Inc.,IPR2013-00109, Paper No.
`
`15.
`
`3 See, for example, Microsoft Corp. v. Proxyconn, Inc.,IPR2013-00109, Paper No.
`
`15.
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`4 See, for example, Arthrex, Inc. v. Bonutti Skeletal Innovations LLC, IPR2013-
`
`00632, Paper No. 23.
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`3
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`relies on evidence not present in the Apple IPR, in fact the Samsung IPR petition
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`relies on evidence, other than patents or printed publications, which is not a
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`competent basis for an inter partes review. Further, despite purporting to rely on
`
`the same grounds as the Apple IPR, Samsung’s use of new evidence actually
`
`introduces new grounds for the proceeding. Thus, Samsung seeks to assert new
`
`grounds for challenging the ‘843 patent after the time period set forth in 37 C.F.R.
`
`§ 42.101(b) has lapsed.
`
`Moreover, Samsung has incorporated these new grounds into its Petition
`
`after having the benefit of analyzing the Apple IPR, Arendi’s Preliminary
`
`Response, and the Patent Trial and Appeal Board’s Decision to Institute the Inter
`
`Partes Review. Supplementation of Apple’s petition with new grounds recited by
`
`Samsung at this stage is not in the interest of justice. As a result, granting
`
`Samsung’s motion for joinder would be prejudicial to Arendi.
`
`Because new evidence compels additional discovery, joinder would also
`
`unduly delay the resolution of the proceeding.
`
`Lastly, the exhibits in the Samsung IPR are inconsistently numbered relative
`
`to exhibits in the Apple IPR.
`
`
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`A. Joinder Would Introduce Subject Matter that Falls Outside the Scope
`of Inter Partes Review
`
` A
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` petitioner for inter partes review may request to cancel as unpatentable
`
`one or more claims of a patent on a ground that could be raised under 35 U.S.C. §
`
`102 or 35 U.S.C. § 103 and only on the basis of prior art consisting of patents or
`
`printed publications. See 35 U.S.C. § 311(b). Although Ground I of Samsung’s
`
`petition purports to rely solely on U.S. Patent No. 5,859,636 to Pandit (“Pandit”),
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`in fact, this ground also relies on evidence that is not competent for challenging
`
`patent claims under inter partes review. Because such evidence falls outside the
`
`scope of inter partes review, the evidence should not be incorporated into the
`
`Apple IPR via joinder.
`
`In addition to Pandit, Ground I relies upon the purported personal
`
`knowledge of Samsung’s expert, Dr. Paul Clark. Dr. Clark’s declaration, in turn, is
`
`used to reference other evidence that is of record neither in the Apple IPR nor in
`
`the Samsung petition. In the absence of disclosure in Pandit of “configured by” 5,
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`Dr. Clark provides testimony concerning his purported personal experience in
`
`configuring window managers, (Ex. 1007, par. 27; Petition, first paragraph of page
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`17), as well as testimony concerning the alleged nature of X Windows in Microsoft
`
`5 “To the extent that building the menus of Pandit does not explicitly disclose that
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`the menu is “configured by” the first application program, …”, Petition at p. 17.
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`5
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`Word 95, without submitting a patent or printed publication describing X Windows
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`or Microsoft Word 95.
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`To read on second information dependent on the type of first information,
`
`the claim chart on p. 18 of the Petition relies upon first information being a phone
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`number and second information being contact information associated with the
`
`phone number. To demonstrate using the phone number (“first information”) as a
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`search term as claimed, the Petition merely states “See narrative below.” Petition,
`
`p. 18. Pandit only discloses an Add to Address Book command without any
`
`disclosure or suggestion of using the phone number in a search. Pandit fails to
`
`disclose allowing a user command to initiate a search using a phone number or any
`
`other contact information (particularly, name-, person-, company- or address-
`
`related information). Instead of relying on Pandit for this missing claim element,
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`Samsung’s narrative recites allegations relating to the operation of Microsoft Mail
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`cloaked as “common sense.” Petition, page 18, 22, 28, and 29. No patent or
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`printed publication is submitted describing Microsoft Mail.
`
`Nowhere does Samsung provide patents or printed publications under 35
`
`U.S.C. § 102 or 35 U.S.C. § 103 to address the missing claim limitations discussed
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`above. In fact, the Petition contains little more than Dr. Clark’s blanket assertions
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`and conclusory remarks about the alleged operations of particular products. In this
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`manner, Ground I relies on products that are not disclosed in patents or printed
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`publications and Dr. Clark’s testimony about those products. Since only patents
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`and printed publications are a competent basis for in an inter partes review, joining
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`the Samsung IPR with the Apple IPR would introduce improper grounds for the
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`proceeding.
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`B. Joinder Would Effectively Introduce New Grounds into the Apple IPR
`
`Although Samsung claims to use the same grounds as the Apple IPR for
`
`challenging the ‘843 patent, in fact, Samsung has augmented the arguments from
`
`the Apple IPR’s Petition (these elaborations have been called out in the table in
`
`Section (D)(i)). As noted above, Samsung seeks to fit Dr. Clark’s statements on
`
`the functionality of X Windows, Microsoft Mail, and Microsoft Word 95 under the
`
`Apple IPR’s rubric of “common sense”. However, by relying on these products,
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`Samsung presents new grounds for invalidity of the claims by asserting alleged
`
`functionalities of X Windows, Microsoft Mail, and/or Microsoft Word 95 in
`
`addition to Pandit, while at the same time shielding these products from analysis
`
`by asserting them only in expert testimony.
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`In this manner, the Samsung IPR reaches beyond the Apple IPR’s remaining
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`ground of obviousness based solely on Pandit. Since the Samsung IPR includes
`
`new grounds for the proceeding, the motion for joinder should be denied.
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`C. Joinder Would Prejudice Arendi
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`In the Apple IPR, Arendi filed its Preliminary Response on March 12, 2014.
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`As noted above, through its new evidence, Samsung is introducing new, albeit
`
`cloaked, grounds for challenge. The new grounds add challenges at a late date
`
`after availing itself of review of Apple’s petition, Arendi’s preliminary response
`
`and the Board’s institution decision. Because joinder would be prejudicial to
`
`Arendi, the motion for joinder should be denied.
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`D. Joinder Would Add Significant Complexity, Delay and Cost to the
`Apple IPR, Thereby Unduly Delaying Its Resolution
`
`i.
`
`Joinder Would Introduce New Evidence
`
`By virtue of using Dr. Paul Clark instead of Dr. Daniel A. Menascé for its
`
`expert, the Samsung IPR includes evidence that is outside of the scope of the
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`Apple IPR. In this manner, the entire declaration and curriculum vitae of Dr. Clark
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`would be new additional evidence that will need to be addressed by Arendi in a
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`joint IPR.6 See Ex. 1007 and 1008. Furthermore, any reliance upon Dr. Clark’s
`
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`6 Although Samsung relies on Dell Inc. v. Network-1 Security Solutions, Inc.,
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`IPR2013-00385, Paper No. 17, and Motorola Mobility LLC v. SoftView LLC,
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`IPR2013-00256, Paper No. 10, to support its motion for joinder, neither case
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`introduced an additional expert subject to be deposed.
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`declaration throughout the Samsung IPR Petition would also be new evidence.
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`Citations to Dr. Clark’s declaration have been set forth in the table below:
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`Page No.
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`Section
`
`5-6
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`6
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`7
`
`12-14
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`17
`
`18
`
`22, 27, 28
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`
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`Section III(D), Claim Construction
`
`Section III(E), Person of Ordinary Skill in the Art
`
`Section III(G), Supporting Evidence
`
`Section V(A), Prior Art – Pandit (U.S. Patent No. 5,859,636),
`arguments regarding Pandit’s alleged operation
`Section V(A), Prior Art – Pandit (U.S. Patent No. 5,859,636),
`arguments regarding configuring the menu by the first application
`program to overcome absence of disclosure in Pandit
`Section V(A), Prior Art – Pandit (U.S. Patent No. 5,859,636),
`arguments regarding searching an address book for duplicate
`entries to overcome absence of disclosure in Pandit
`Section V(A), Prior Art – Pandit (U.S. Patent No. 5,859,636),
`arguments regarding enabling a user to call a person with an
`identified name by searching the address book, and, if the name
`corresponded to multiple numbers in the address book, displaying
`them for selection to overcome absence of disclosure in Pandit
`
`Additionally, by virtue of using the Merriam-Webster’s Collegiate®
`
`Dictionary, the Samsung IPR includes further evidence that is outside of the scope
`
`of the Apple IPR. In this manner, the definition of “configure” provided by this
`
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`dictionary is new evidence for the Apple IPR, as well as any reliance on this
`
`definition found in the Samsung IPR Petition. See Ex. 1009; see also Petition,
`
`page 5.
`
`Therefore, for at least the forgoing reasons, joining the Samsung IPR to the
`
`Apple IPR would introduce new evidence into the proceeding.
`
`
`
`ii.
`
`Joinder Would Expand and Complicate Discovery
`
`In keeping with the Board’s interest in delivering an inexpensive resolution
`
`to an IPR, discovery is strictly limited. 37 C.F.R. § 42.51(b). Nevertheless, cross
`
`examination of affidavit testimony is routine discovery. The Samsung IPR would
`
`add the testimony of a new witness, Dr. Paul Clark. Additional testimony from
`
`Arendi’s witness(es) would also be expected. These witnesses will be asked to
`
`address all of the new issues mentioned herein that would be imposed by the
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`Samsung IPR. The added difficulties of scheduling, preparing for and attending
`
`these depositions would bog down and significantly increase the cost of
`
`prosecuting the Apple IPR.
`
`Further, statements in Dr. Clark’s declaration would compel discovery
`
`beyond the scope originally required by the Apple IPR. Because Dr. Clark has
`
`characterized products that were purportedly available contemporaneously with the
`
`filing of the ‘843 patent without having made any objective information about
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`those products available to the Patent Owner, joinder with the Apple IPR would
`
`require investigation into those products. As a beginning matter, Samsung must
`
`produce the products, including “X Windows”, “Microsoft Mail”, and “Microsoft
`
`Word 95”, so that Patent Owner can examine their functionality, and evaluate the
`
`claims being made by Dr. Clark. At the very least, product specifications, user
`
`manuals, marketing materials, and trade publications should be produced. But to
`
`the extent printed publications might be relied upon, these would raise new
`
`grounds outside the scope of the Apple IPR. Without sufficient discovery of the
`
`products discussed by Dr. Clark, Patent Owner would be prejudiced by the
`
`introduction of the Clark declaration.
`
`Therefore, for at least the forgoing reasons, joining the Samsung IPR to the
`
`Apple IPR would expand and complicate discovery in the proceeding.
`
`
`
`iii.
`
`Joinder Would Disrupt the Schedule of the Apple IPR, Leading to
`Undue Delays in Reaching Final Decision
`
`Arendi has already scheduled a deposition for Dr. Menasce, the expert used
`
`in the Apple IPR, for Thursday, August 7, 2014. If the Samsung IPR were joined
`
`to the Apple IPR, Arendi would also need to depose Dr. Clark regarding the results
`
`of discovery with respect to, among other things, X Windows, Microsoft Mail, and
`
`Microsoft Word 95. Both discovery and preparation for the Clark deposition
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`would require a substantial amount of time and effort, and neither has commenced
`
`yet. Since the Apple IPR is already in progress, joining the Samsung IPR would
`
`disrupt the schedule of the Apple IPR. In fact, such joinder would require
`
`significant revisions to the schedule to accommodate the expanded discovery
`
`required by the Samsung IPR. Therefore, for at least the forgoing reasons, joining
`
`the Samsung IPR to the Apple IPR would disrupt the Apple IPR, leading to undue
`
`delays in its resolution.
`
`
`
`iv. Samsung has Improperly Numbered the Exhibits for its IPR
`
`Because the exhibits in the Samsung IPR are not consistently numbered with
`
`the exhibits in the Apple IPR, joining the two cases would require renumbering
`
`and relabeling of some exhibits, which would delay the proceedings.
`
`In particular, the Office Action in the prosecution of the ’843 patent, dated
`
`October 28, 2010 was numbered as Ex. 1002 in the Samsung IPR, but Ex. 1004 in
`
`the Apple IPR. Applicant’s response in prosecution of the ’843 patent, dated
`
`December 8, 2010, was numbered as Ex. 1003 in the Samsung IPR, but Ex. 1005
`
`in the Apple IPR. The amendment in prosecution of the ’854 patent, dated January
`
`24, 2008, was numbered as Ex. 1004 in the Samsung IPR, but Ex. 1003 in the
`
`Apple IPR. Finally, U.S. Patent No. 5,859,636 (“Pandit”) was numbered as Ex.
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`1005 in the Samsung IPR, but Ex. 1009 in the Apple IPR. Therefore, for at least
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`the forgoing reasons, joining the Samsung IPR to the Apple IPR would introduce
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`an administrative burden that would delay the proceedings of the Apple IPR.
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`
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`IV. Conclusion
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`For all the foregoing reasons, Samsung’s motion for joinder should be
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`denied and the Board should proceed to an orderly and timely consideration of the
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`Apple IPR.
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`
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`Dated: August 4, 2014
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` Respectfully submitted,
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`03324/00509 2140324.1
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`
` /Robert M. Asher, #30,445/
`Robert M. Asher, Reg. No. 30,445
`Bruce D. Sunstein, Reg. No. 27,234
`John J. Stickevers, Reg. No. 39,387
`Dorothy Wu, Reg. No. 69,535
` Sunstein Kann Murphy & Timbers LLP
`th Floor
` 125 Summer Street, 11
` Boston, MA 02110-1618
`(617) 443-9292
`Attorney for Patent Owner, Arendi S.A.R.L.
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`13
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`CERTIFICATE OF SERVICE
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` It is certified that on August 4, 2014, a copy of Arendi’s Opposition to
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`Motion for Joinder has been served on Petitioner as provided in 37 C.F.R. §
`
`42.6(e) via electronic mail addressed to counsel of record for Petitioners at the
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`following addresses:
`
`
`
`LEAD COUNSEL FOR PETITIONER
`SAMSUNG
`
`ANDREA G. REISTER
`areister@cov.com
`Registration No. 36,253
`COVINGTON & BURLING LLP
`1201 Pennsylvania Avenue NW
`Washington, DC 20004
`Tel: (202) 662-5141
`Fax: (202) 778-5141
`
`
`
`BACK-UP COUNSEL FOR
`PETITIONER SAMSUNG
`
`GREGORY S. DISCHER
`gdischer@cov.com
`Registration No. 42,488
`COVINGTON & BURLING LLP
`1201 Pennsylvania Avenue NW
`Washington, DC 20004
`Tel: (202) 662-5141
`Fax: (202) 778-5141
`
`
`Date: August 4, 2014
`
` /Robert M. Asher, #30,445 /
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`
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`
`
` Robert M. Asher
`Registration No. 30,445
`Sunstein Kann Murphy & Timbers LLP
`125 Summer Street
`Boston, MA 02110
`Tel: (617) 443-9292
`Fax: (617) 443-0004
`
`
`
`
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