UNITED STATES PATENT AND TRADEMARK OFFICE
`
`———————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`———————
`
`CISCO SYSTEMS, INC.,
`
`Petitioner
`
`v.
`
`HEWLETT PACKARD ENTERPRISE COMPANY,
`
`Patent Owner
`
`———————
`
`Case IPR2017-01933
`
`Patent 8,478,799
`
`PETITIONER’S REPLY
`
`TO PATENT OWNER’S PRELIMINARY RESPONSE
`
`
`
`
`
`
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`
`
`
`
`
`
`
`
`
`———————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`———————
`
`CISCO SYSTEMS, INC.,
`
`Petitioner
`
`v.
`
`HEWLETT PACKARD ENTERPRISE COMPANY,
`
`Patent Owner
`
`———————
`
`Case IPR2017-01933
`
`Patent 8,478,799
`
`PETITIONER’S REPLY
`
`TO PATENT OWNER’S PRELIMINARY RESPONSE
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Petitioner’s Reply to Patent Owner’s Preliminary Response
`IPR2017-01933 (U.S. Patent 8,478,799)
`Petitioner thanks the Board for the opportunity provided in the Order issued
`
`February 21, 2018 (Paper 7) to respond to the real party-in-interest allegations
`
`made in Patent Owner’s Preliminary Response (“POPR,” Paper 6).
`
`Petitioner reaffirms that the Petition (“Pet.,” Paper 1) correctly named only
`
`Cisco Systems, Inc. (“Cisco”) as a real party-in-interest. Springpath, Inc.
`
`(“Springpath”) did not participate in, fund, direct, or control the preparation or
`
`filing of the petition, and Cisco and Springpath were not in privity as of the filing
`
`date. Patent Owner’s allegations are without evidence and without merit.
`
`A. Relevant Facts
`
`Cisco filed its petition in this case before it agreed to acquire Springpath,
`
`before it announced its intent to do so, and before it completed that acquisition:
`
` Aug. 11, 2017: Cisco filed the petition in this case. See Paper 1.
`
` Aug. 19, 2017: Cisco agreed to acquire Springpath. Ex. 1063 at 2.
`
` Aug. 21, 2017: Cisco announced an intent to acquire Springpath. Ex. 2002.
`
` Sept. 22, 2017: Cisco acquired Springpath. Ex.1062 at 1; Ex. 1064 at 2-3.
`
`B.
`
`The Petition is Complete Because Springpath was Not a Real
`Party-in-Interest at the Time of Filing
`
`The Board should not deny the Petition because it properly identifies Cisco
`
`as the only real party-in-interest at the time of filing. Pet. at 13; see POPR at 2;
`
`see also 35 U.S.C. § 312(a)(2) and 37 C.F.R. § 42.8(b)(1).
`
`The Board’s precedent clarifies that whether a party is a real party-in-interest
`
`2
`
`
`
`Petitioner’s Reply to Patent Owner’s Preliminary Response
`IPR2017-01933 (U.S. Patent 8,478,799)
`depends on “the relationship between a party and a proceeding” not “the
`
`relationship between parties.” Aruze Gaming Macau, Ltd. v. MGT Gaming, Inc.,
`
`IPR2014-01288, Paper 13 at 11 (PTAB Feb. 20, 2015). The Office Patent Trial
`
`Practice Guide also provides factors for determining whether a party is a real party
`
`in interest such as whether a non-party exercises control over a petitioner’s
`
`participation in a proceeding or whether a non-party is funding or directing the
`
`proceeding. 77 Fed. Reg. 48,756, 48,759-60 (Aug. 14, 2012).
`
`Here, there is no evidence to show that Springpath has controlled, funded, or
`
`directed this proceeding, had the opportunity to control this proceeding, or was
`
`involved in any way in initiating this proceeding. Therefore, Springpath is not a
`
`real party-in-interest. Id.; see also Aruze Gaming at 11-12. Further, there is no
`
`evidence to show that Springpath influenced, or sought to influence, Cisco’s
`
`independent decision to initiate this proceeding. Thus, Springpath is not
`
`impermissibly “litigating through a proxy.” Aruze Gaming at 12.
`
`Patent Owner’s argument is empty because there is no supporting evidence.
`
`POPR at 6. Patent Owner’s arguments, unsupported by evidence, fail to rebut the
`
`presumption that Cisco’s Petition accurately identifies all real parties-in-interest.
`
`See Medtronic, Inc. v. Robert Bosch Healthcare Sys., Inc., Case IPR2014-00488,
`
`Paper 52 at 6-7 (PTAB Mar. 16, 2015).
`
`Patent Owner’s cited cases are readily distinguished on the facts. First, in the
`
`3
`
`
`
`Petitioner’s Reply to Patent Owner’s Preliminary Response
`IPR2017-01933 (U.S. Patent 8,478,799)
`Medtronic case, Medtronic filed a petition after completing the acquisition of
`
`Cardiocom. Medtronic at 3-4. The evidence also showed that Cardiocom had
`
`funded preparation of Medtronic’s petitions. Medtronic at 14. In stark contrast,
`
`Cisco filed the instant Petition before even announcing its intent to acquire
`
`Springpath and a month before completing the acquisition. There is also no
`
`evidence that Springpath funded any activity related to this proceeding. Thus, this
`
`case is nothing like the facts of Medtronic.
`
`The RPX v. VirnetX case is also factually unlike this case. There, the Board
`
`found that Apple discussed a proposal with RPX to challenge patents through inter
`
`partes review and provided $500,000 to fund RPX’s efforts. See IPR2014-00171,
`
`Paper 57 at 4-5 (PTAB July 14, 2014). The Board also found that Apple made
`
`available its counsel and expert to RPX. Id. at 7. Here, no evidence has been
`
`submitted of such interactions between Springpath and Cisco. Cisco filed the
`
`Petition for its own reasons, not as a proxy for Springpath.
`
`Accordingly, the Petition properly named only Cisco as the real party-in-
`
`interest. Patent Owner’s allegation that Cisco’s Petition was incomplete is
`
`therefore not correct. See Lumentum v. Capella, IPR2015-00739, Paper 38 at 6
`
`(Mar. 4, 2016) (precedential). Cisco’s Petition was complete when filed.
`
`C. Cisco and Springpath Were Not in Privity at the Time of Filing
`
`Moreover, because Springpath and Cisco were not in privity when Cisco
`
`4
`
`
`
`Petitioner’s Reply to Patent Owner’s Preliminary Response
`IPR2017-01933 (U.S. Patent 8,478,799)
`filed the Petition, denial of Cisco’s Petition would unfairly deprive Cisco of a full
`
`and fair opportunity to litigate validity of the ’799 patent—an opportunity Cisco
`
`has not had before. See Aruze Gaming at 13.
`
`The Board has repeatedly found that “it is only privity relationships up until
`
`the time a petition is filed that matter; any later-acquired privies are irrelevant.”
`
`Semiconductor Components Indus. v. Power Integrations, Inc., Case IPR2016-
`
`00995, Paper 26 at 10 (PTAB Oct. 18, 2017) (quoting Synopsys, Inc. v. Mentor
`
`Graphics Corp., Case IPR2012-00042, Paper 60 at 12 (PTAB Feb. 19, 2014)).
`
`In a case where a petitioner filed its petition and (like here) later acquired a
`
`third party, the Board held that §315(b) did not bar institution. See Arris Group,
`
`Inc. v. TQ Delta, LLC, IPR2016-00430, Paper 9 at 6-7 (PTAB July 1, 2016). In
`
`Arris, the Board considered evidence that the petitioner was in the process of
`
`acquiring a third party and had a common defense agreement with the third party,
`
`but found that the petitioner had no control over the third party. Id.
`
`Here, Cisco filed its Petition before acquiring Springpath. There is no
`
`evidence to suggest that as of the petition filing date Cisco had control over, or the
`
`legal right to assume control over, Springpath, or vice versa. Indeed, Cisco and
`
`Springpath had not even agreed to an acquisition, let alone completed it. Patent
`
`Owner’s attempt to use Cisco’s option to acquire Springpath to imply a privity
`
`relationship is unsupported by facts or applicable law. Even an acquisition
`
`5
`
`
`
`Petitioner’s Reply to Patent Owner’s Preliminary Response
`IPR2017-01933 (U.S. Patent 8,478,799)
`agreement does not create privity, much less an option to acquire. See Arris at 6-7.
`
`Patent Owner’s reference to common interest privilege is irrelevant because
`
`“undertaking a joint defense and assertion of a common interest privilege does not,
`
`without more, indicate privity.” Petroleum Geo-Services, Inc. v. WesternGeco,
`
`LLC, IPR2014-01475, slip op. at 19 (Mar. 17, 2015); see also Weatherford Int’l v.
`
`Packers Plus Energy Svcs., Inc., IPR2016-01517, Paper 23 at 14 (Feb. 23, 2017).
`
`Patent Owner does not allege that any of the Taylor factors imply privity
`
`between Cisco and Springpath, and none of those factors applies here. Nonparty
`
`preclusion cannot be based on mere “identity of interests and some kind of
`
`relationship between parties and nonparties.” See Taylor v. Sturgell, 553 U.S. 880,
`
`901 (2008). Control is an important factor to establish privity. Id. at 893-95. But
`
`Patent Owner offers no argument—let alone any evidence—of the “control” factor.
`
`D. Conclusion
`
`Because Cisco was properly named as the sole real party-in-interest, and
`
`because Cisco and Springpath were not in privity as of the filing date, § 315(b)
`
`does not bar institution of Cisco’s Petition.
`
`Petitioner believes that its original identification of Cisco as the sole real
`
`party-in-interest remains correct today. If the Board believes that, as a result of the
`
`acquisition, Cisco should file updated mandatory notices including Springpath as a
`
`real party-in-interest, Cisco will comply with such a request or order.
`
`6
`
`
`
`Petitioner’s Reply to Patent Owner’s Preliminary Response
`IPR2017-01933 (U.S. Patent 8,478,799)
`Respectfully submitted,
`
`/David L. McCombs/
`David L. McCombs
`Counsel for Petitioner
`Registration No. 32,271
`
`
`
`
`
`
`
`February 28, 2017
`
`
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`
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`
`7
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`
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`Petitioner’s Reply to Patent Owner’s Preliminary Response
`IPR2017-01933 (U.S. Patent 8,478,799)
`PETITIONER’S EXHIBIT LIST
`
`1001
`
`1002
`
`1003
`
`1004
`
`1005
`
`1006
`
`1007
`
`February 28, 2018
`
`U.S. Patent No. 8,478,799 (“the ’799 patent”)
`
`Prosecution History of the ’799 patent
`
`U.S. Prov. App. No. 61/269,633 (“the ’633 provisional”)
`
`Declaration of Dr. Prashant Shenoy Under 37 C.F.R. § 1.68
`
`Curriculum Vitae of Dr. Prashant Shenoy
`
`Intentionally omitted
`
`Athicha Muthitacharoen, et al., “Ivy: A Read/Write Peer-to-Peer
`
`File System,” Proceedings of the 5th Symposium on Operating
`
`Systems Design and Implementation (OSDI ’02), OPERATING
`
`SYSTEMS REVIEW, Vol. 36, Issue SI (Winter 2002).
`
`1008
`
`Frank Dabek, et al., “Wide-area cooperative storage with CFS,”
`
`Proceedings of the 18th ACM Symposium on Operating Systems
`
`Principles (SOSP’01), OPERATING SYSTEMS REVIEW, Vol. 35, No. 5
`
`(Dec. 2001).
`
`1009
`
`Nitin Agrawal, et al., “Design Tradeoffs for SSD Performance,”
`
`USENIX’08: 2008 USENIX Annual Technical Conference (Jun. 25,
`
`2008).
`
`1010
`
`U.S. Patent No. 8,028,106 to Bondurant et al. (“Bondurant”)
`
`8
`
`
`
`Petitioner’s Reply to Patent Owner’s Preliminary Response
`IPR2017-01933 (U.S. Patent 8,478,799)
`Marshall Kirk McKusick, et al., THE DESIGN AND IMPLEMENTATION
`
`1011
`
`OF THE FREEBSD OPERATING SYSTEM (2005).
`
`1012
`
`“Robust and Efficient Data Management for a Distributed Hash
`
`Table” by Josh Cates (“Cates”).
`
`1013
`
`Marice J. Bach, THE DESIGN OF THE UNIX OPERATING SYSTEM
`
`(1986) (selected pages).
`
`1014
`
`Prashant Shenoy, et al., “Symphony: An Integrated Multimedia File
`
`System,” Proceedings of SPIE 3310, Multimedia Computing and
`
`Networking 1998.
`
`1015
`
`Garth Gibson, et al., “A Cost-Effective, High-Bandwidth Storage
`
`Architecture,” PROCEEDINGS OF THE 8TH CONFERENCE ON
`
`ARCHITECTURAL SUPPORT FOR PROGRAMMING LANGUAGES AND
`
`OPERATING SYSTEMS (1998).
`
`1016
`
`Mike Mesnier, et al., “Object-Based Storage,” IEEE
`
`COMMUNICATION MAGAZINE (Aug. 2003).
`
`1017
`
`R. Rivest, “The MD5 Message-Digest Algorithm,” Request for
`
`Comments 1321, Internet Engineering Task Force (Apr. 1992).
`
`9
`
`
`
`1018
`
`1019
`
`1020
`
`1021
`
`1022
`
`1023
`
`1024
`
`Petitioner’s Reply to Patent Owner’s Preliminary Response
`IPR2017-01933 (U.S. Patent 8,478,799)
`Sean Quinlan, et al., “Venti: a new approach to archival storage,”
`
`PROCEEDINGS OF FAST 2002 CONFERENCE OF FILE AND STORAGE
`
`TECHNOLOGIES (2002).
`
`Petition for Inter Partes Review, IPR2016-01779 (Sept. 14, 2016).
`
`Patent Owner Response, IPR2016-01779 (Dec. 27, 2016).
`
`Petition for Inter Partes Review, IPR2016-01780 (Sept. 14, 2016).
`
`Patent Owner Response, IPR2016-01780 (Dec. 27, 2016).
`
`Bruce Eckel, C++ INSIDE & OUT (1992) (selected pages).
`
`Mendel Rosenblum, THE DESIGN AND IMPLEMENTATION OF A LOG-
`
`STRUCTURED FILE SYSTEM (1995) (selected pages).
`
`1025
`
`WEBSTER’S NEW WORLD COMPUTER DICTIONARY, 10th Ed. (2003)
`
`(selected pages).
`
`1026
`
`MICROSOFT COMPUTER DICTIONARY, 5th Ed. (2002) (selected
`
`pages).
`
`1027
`
`1028
`
`AMD Athlon Processor Technical Brief, Rev. D (Dec. 1999).
`
`Stevens, et al., “The first collision for full SHA-1,” Cryptology
`
`ePrint Archive, Report 2017/190 (2017).
`
`1029
`
`Andrew S. Tanenbaum, MODERN OPERATING SYSTEMS, 2d Ed.
`
`(2001) (selected pages).
`
`10
`
`
`
`Petitioner’s Reply to Patent Owner’s Preliminary Response
`IPR2017-01933 (U.S. Patent 8,478,799)
`Alan Freedman, COMPUTER DESKTOP ENCYCLOPEDIA, 9th Ed. (2001)
`
`1030
`
`(selected pages).
`
`1031
`
`Sang-Won Lee, et al., “A Case for Flash Memory SSD in Enterprise
`
`Database Applications,” Proceedings of the 2008 ACM SIGMOD
`
`International Conference on Management of Data (2008).
`
`1032
`
`Bruce Schneier, APPLIED CRYPTOGRAPHY, 2d Ed. (1996) (selected
`
`pages).
`
`1033
`
`Martin Placek, “Storage Exchange: A Global Platform for Trading
`
`Distributed Storage Services,” Master of Engineering Science
`
`Thesis, The University of Melbourne (Jul, 2006).
`
`1034
`
`Ragib Hasan, et al., “A Survey of Peer-to-Peer Storage Techniques
`
`for Distributed File Systems,” International Conference on
`
`Information Technology: Coding and Computing (2005).
`
`1035
`
`Frequently Asked Questions for FreeBSD 2.X, 3.X and 4.X,
`
`archived at https://web.archive.org/web/20020404064240/http://
`
`www.freebsd.org:80/doc/en_US.ISO8859-1/books/faq/install.html.
`
`AMD Athlon Processor Module Data Sheet, Rev. M (Jun. 2000).
`
`AMD Athlon™ Processor Quick Reference FAQ (Feb. 3, 2000).
`
`U.S. Patent No. 7,103,595 to Anastasiadis, et al.
`
`1036
`
`1037
`
`1038
`
`11
`
`
`
`Petitioner’s Reply to Patent Owner’s Preliminary Response
`IPR2017-01933 (U.S. Patent 8,478,799)
`U.S. Patent No. 8,140,786 to Bunte et al.
`
`Decision Denying Institution of Inter Partes Review, IPR2016-
`
`1039
`
`1040
`
`01779 (March 22, 2017).
`
`1041
`
`Decision Denying Institution of Inter Partes Review, IPR2016-
`
`01780 (March 21, 2017).
`
`1042
`
`MARC Record Information for Operating Systems Review –
`
`Proceedings of the Fifth ACM Symposium on Operating Systems
`
`Design and Implementation (OSDI’02), available at the WRLC
`
`online catalog, accessed July 20, 2017.
`
`1043
`
`Bibliographic Record Information for Operating Systems Review –
`
`Proceedings of the Fifth ACM Symposium on Operating Systems
`
`Design and Implementation (OSDI’02), available at the WRLC
`
`online catalog, accessed July 20, 2017.
`
`1044
`
`MARC Record Information for Operating Systems Review –
`
`Proceedings of the 18th ACM Symposium on Operating Systems
`
`Principles (SOSO’01), available at the online catalog of the Library
`
`of Congress, accessed July 31, 2017.
`
`12
`
`
`
`Petitioner’s Reply to Patent Owner’s Preliminary Response
`IPR2017-01933 (U.S. Patent 8,478,799)
`Bibliographic Record Information for Operating Systems Review –
`
`1045
`
`Proceedings of the 18th ACM Symposium on Operating Systems
`
`Principles (SOSO’01), available at the online catalog of the Library
`
`of Congress, accessed July 31, 2017.
`
`1046
`
`Scans of Issue, Operating Systems Review – Proceedings of the 18th
`
`ACM Symposium on Operating Systems Principles (SOSO’01), Vol.
`
`35, No. 5, pp. 202-15, obtained from a CD-ROM from Auburn
`
`University.
`
`1047
`
`MARC Record Information for Operating Systems Review –
`
`Proceedings of the 18th ACM Symposium on Operating Systems
`
`Principles (SOSO’01) CD-ROM, available at the Auburn University
`
`Library online catalog, accessed July 28, 2017.
`
`1048
`
`Bibliographic Record Information for Operating Systems Review –
`
`Proceedings of the 18th ACM Symposium on Operating Systems
`
`Principles (SOSO’01) CD-ROM, available at the Auburn University
`
`Library online catalog, accessed July 28, 2017.
`
`1049
`
`Scan of CD-ROM and CD-ROM Case, Operating Systems Review –
`
`Proceedings of the 18th ACM Symposium on Operating Systems
`
`Principles (SOSO’01) CD-ROM obtained from the Auburn
`
`University Library.
`
`13
`
`
`
`Petitioner’s Reply to Patent Owner’s Preliminary Response
`IPR2017-01933 (U.S. Patent 8,478,799)
`Byung-Gon Chun, et al., “Efficient Replica Maintenance for
`
`1050
`
`Distributed Storage Systems,” PROCEEDINGS OF NSDI ’06: 3RD
`
`SYMPOSIUM ON NETWORKED SYSTEMS DESIGN & IMPLEMENTATION
`
`(2006).
`
`1051
`
`Scanned pages of Dabek, F., et al., 2001, “Wide-area cooperative
`
`storage with CFS,” Operating Systems Review – Proceedings of the
`
`18th ACM Symposium on Operating Systems Principles (SOSO’01),
`
`Vol. 35, No. 5, pp. 202-15, obtained from a CD-ROM from Auburn
`
`1052
`
`1053
`
`1054
`
`1055
`
`1056
`
`1057
`
`University.
`
`Intentionally omitted.
`
`Intentionally omitted.
`
`Declaration of Ingrid Hsieh-Yee, PhD Under 37 C.F.R. § 1.68
`
`Declaration of Michele Nelson Under 37 C.F.R. § 1.68
`
`Declaration of David Bader Under 37 C.F.R. § 1.68
`
`MARC Record Information for THE DESIGN AND IMPLEMENTATION
`
`OF THE FREEBSD OPERATING SYSTEM (2005), available at the online
`
`catalog of the Library of Congress, accessed August 3, 2017.
`
`14
`
`
`
`Petitioner’s Reply to Patent Owner’s Preliminary Response
`IPR2017-01933 (U.S. Patent 8,478,799)
`Bibliographic Record Information for THE DESIGN AND
`
`1058
`
`IMPLEMENTATION OF THE FREEBSD OPERATING SYSTEM (2005),
`
`available at the online catalog of the Library of Congress, accessed
`
`August 3, 2017.
`
`1059
`
`Scanned pages of Marshall Kirk McKusick, et al., THE DESIGN AND
`
`IMPLEMENTATION OF THE FREEBSD OPERATING SYSTEM (2005),
`
`obtained from the George Mason University Library.
`
`1060
`
`MARC Record Information for THE DESIGN AND IMPLEMENTATION
`
`OF THE FREEBSD OPERATING SYSTEM (2005), available at the online
`
`catalog of the George Mason University Library, accessed August 3,
`
`2017.
`
`1061
`
`Bibliographic Record Information for THE DESIGN AND
`
`IMPLEMENTATION OF THE FREEBSD OPERATING SYSTEM (2005),
`
`available at the online catalog of the George Mason University
`
`Library, accessed August 3, 2017.
`
`1062
`
` “Cisco Completes Acquisition of Springpath” (Sept. 22, 2017),
`
`available at https://www.cisco.com/c/en/us/about/corporate-
`
`strategy-office/acquisitions/springpath.html.
`
`15
`
`
`
`Petitioner’s Reply to Patent Owner’s Preliminary Response
`IPR2017-01933 (U.S. Patent 8,478,799)
`Agreement and Plan of Merger by and Among Cisco Systems, Inc.,
`
`1063
`
`Leap Acquisition Corp., Springpath, Inc. and The Stockholders’
`
`Agent (Aug. 19, 2017) (selected pages, redacted).
`
`1064
`
`Certificate of Merger for the Merger of Leap Acquisition Corp. with
`
`and into Springpath, Inc. (Sept. 22, 2017).
`
`16
`
`
`
`
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`Petition for Inter Partes Review
`
`IPR2017-01933
`U.S. Patent No. 8,478,799
`
`
`§§§§§
`
`Cisco Systems, Inc.
`
`Petitioner
`v.
`Hewlett Packard Enterprise Co.,
`
`Patent Owner
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies, in accordance with 37 C.F.R. § 42.6, that service
`was made on the Patent Owner as detailed below.
`Date of service February 28, 2018
`
`Manner of service Electronic Service by E-Mail:
`bshelton@sheltoncoburn.com; srikala.p.atluri@hpe.com;
`IPRs@sheltoncoburn.com
`
`Documents served Petitioner’s Reply to Patent Owner’s Preliminary Response
`and Exhibits 1062-1064
`
`Persons served Barry K. Shelton
`SHELTON COBURN LLP
`311 RR 620 S, Suite 205
`Austin, TX 78734
`
`Srikala P. Atluri
`HEWLETT PACKARD ENTERPRISE CO.
`1400 Liberty Ridge Drive, Suite 105
`Wayne, PA 19087
`
`/David L. McCombs/
`David L. McCombs
`Counsel for Petitioner
`Registration No. 32,271
`
`
`
`17
`
`
`
`
`
`
`
`
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