IPR2018-01511
`Petitioner’s Reply to Patent Owner’s Preliminary Response
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`CISCO SYSTEMS, INC.,
`Petitioner,
`
`v.
`
`CHRIMAR SYSTEMS, INC.,
`Patent Owner
`
`Case No. IPR2018-01511
`Patent 8,902,760 B2
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`
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`PETITIONER’S REPLY TO PATENT OWNER’S PRELIMINARY
`RESPONSE
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`Petitioner’s Reply to Patent Owner’s Preliminary Response
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`CISCO SYSTEMS, INC.,
`Petitioner,
`
`v.
`
`CHRIMAR SYSTEMS, INC.,
`Patent Owner
`
`Case No. IPR2018-01511
`Patent 8,902,760 B2
`
`
`
`PETITIONER’S REPLY TO PATENT OWNER’S PRELIMINARY
`RESPONSE
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`IPR2018-01511
`Petitioner’s Reply to Patent Owner’s Preliminary Response
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`TABLE OF CONTENTS
`I.
`INTRODUCTION ........................................................................................... 1
`BACKGROUND ............................................................................................. 3
`II.
`III. CLICK-TO-CALL DOES NOT BAR INSTITUTION .................................... 4
`IV. CONCLUSION ................................................................................................ 7
`
`
`
`
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`i
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`IPR2018-01511
`Petitioner’s Reply to Patent Owner’s Preliminary Response
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`TABLE OF AUTHORITIES
`
` Page(s)
`
`Cases
`Cisco Sys., Inc. et al v. ChriMar Sys., Inc.,
`15-cv-10817, Dkt. 1 (E.D. Mich. Mar. 5, 2015) ................................................... 3
`Cisco Sys., Inc. et al v. ChriMar Sys., Inc.,
`15-cv-10817, Dkt. 16 (E.D. Mich. Feb. 17, 2018) ............................................... 3
`Click-To-Call Techs., LP v. Ingenio, Inc.,
`899 F.3d 1321 (Fed. Cir. 2018) ...................................................................passim
`Clio USA, Inc.,
`No. IPR2013-00438, Paper 9 (P.T.A.B. Jan. 9, 2014) ..................................... 2, 7
`RaceTires Am., Inc. v. Hoosier Racing Tire Corp.,
`674 F.3d 158 (3d Cir. 2012) ................................................................................. 5
`Statutes
`35 U.S.C. § 315 .................................................................................................passim
`Rules
`Fed. R. Civ. P. 41(a) ................................................................................................... 1
`Other Authorities
`157 Cong. Rec. S1023 (March 1, 2011) .................................................................... 6
`9 Wright & Miller, Federal Prac. and Proc. § 2367 (3d. ed. 2018) ........................... 6
`Black’s Law Dictionary (10th ed. 2014) ................................................................... 2
`
`
`
`ii
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`IPR2018-01511
`Petitioner’s Reply to Patent Owner’s Preliminary Response
`
`
`Exhibit
`No.
`1001 Declaration of George Zimmerman Under 37 C.F.R. § 1.68 in
`Support of Petition for Inter Partes Review of U.S. Patent
`Nos. 8,155,012, 8,902,760; 9,049,019; and 9,812,825
`1002 Curriculum Vitae of George Zimmerman
`1003 U.S. Patent No. 8,155,012
`1004 U.S. Patent No. 8,902,760
`1005 U.S. Patent No. 9,049,019
`1006 U.S. Patent No. 9,812,825
`1007
`Final Written Decision regarding U.S. Patent No. 8,155,012,
`Juniper Networks, Inc. v. ChriMar Sys., Inc., IPR2016-01389,
`Paper No. 69 (P.T.A.B. Jan. 23, 2018)
`Final Written Decision regarding U.S. Patent No. 8,942,107,
`Juniper Networks, Inc. v. ChriMar Sys., Inc., IPR2016-01391,
`Paper No. 66 (P.T.A.B. Dec. 20, 2017)
`Final Written Decision regarding U.S. Patent No. 9,019,838,
`Juniper Networks, Inc. v. ChriMar Sys., Inc., IPR2016-01397
`Paper No. 66 (P.T.A.B. Dec. 29, 2017)
`Final Written Decision regarding U.S. Patent No. 8,902,760,
`Juniper Networks, Inc. v. ChriMar Sys., Inc., IPR2016-01399
`Paper No. 73 (P.T.A.B. Apr. 26, 2018)
`1011 Oral hearing transcript, August 31, 2017, Juniper Networks,
`Inc. v. ChriMar Sys., Inc., IPR2016-01389, 1391, 1397, 1399.
`1012 Opinion, ChriMar Holding Company, LLC, ChriMar Systems,
`Inc. dba CMA Technologies, Inc v. ALE USA Inc., fka Alcatel-
`Lucent Enterprise USA, Inc., 17-1848, Dkt. No. 55 (May 8,
`2018)
`1013 Memorandum Opinion and Order, Chrimar Sys., Inc., et al. v.
`Alcatel-Lucent S.A. et al., Civil Action No. 6:15-cv-163-JDL,
`Eastern District of Texas, Dkt. No. 122, March 28, 2016
`1014 Defendant’s Answer, Affirmative Defenses, Jury Demand and
`Counterclaim to First Amended Complaint, Cisco Sys., Inc. v.
`ChriMar Sys. Inc., 2:17-cv-13770, Dkt. 22 (E.D. Mich. Mar.
`16, 2018)
`
`1008
`
`1009
`
`1010
`
`PETITIONER’S EXHIBIT LIST
`
`Description
`
`iii
`
`Previously
`Submitted
`X
`
`X
`X
`X
`X
`X
`X
`
`X
`
`X
`
`X
`
`X
`
`X
`
`X
`
`X
`
`
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`IPR2018-01511
`Petitioner’s Reply to Patent Owner’s Preliminary Response
`
`Description
`
`Previously
`Submitted
`X
`X
`X
`X
`X
`X
`X
`X
`X
`
`X
`X
`X
`X
`X
`X
`X
`X
`X
`X
`X
`
`X
`
`X
`
`X
`
`X
`
`Exhibit
`No.
`1015
`1016
`1017
`1018
`1019
`1020
`1021
`1022
`1023
`
`List of Pending Cases Involving U.S. Patent No. 8,155,012
`List of Pending Cases Involving U.S. Patent No. 8,902,760
`List of Pending Cases Involving U.S. Patent No. 9,049,019
`List of Pending Cases Involving U.S. Patent No. 9,812,825
`IEEE 802.3-1985
`IEEE 802.3i-1990
`IEEE 802.3u-1995
`IEEE International Standard ISO/IEC 8802-3: 1993
`IEEE Standards Association News & Events: Press Releases
`“IEEE 802.3 Standard for Ethernet Marks 30 Years of
`Innovation and Global Market Growth”
`1024 Declaration of Jennifer A. Babbitt
`1025 U.S. Patent No. 4,173,714 to Bloch et al.
`1026 U.S. Patent No. 4,823,070 to Nelson
`1027 U.S. Patent No. 5,089,927 to Bulan et al.
`1028 U.S. Patent No. 5,994,998 to Fisher
`1029 U.S. Patent No. 6,115,468 to De Nicolo
`1030 U.S. Patent No. 6,140,911 to Fisher
`1031 U.S. Patent No. 6,247,058 to Miller et al.
`1032 U.S. Patent No. 6,865,152 to Luhmann
`1033 WO 96/23377 to Hunter
`1034
`Swiss Patent No. CH 643 095 A5 to Peguiron, Certified Copy
`of an English Translation Version of CH 643 095 A5, and
`Declaration of John E. Dawson
`Ex Parte Reexamination Certificate for U.S. Patent No.
`8,902,760, September 18, 2017
`Ex Parte Reexamination Advisory Action for U.S. Patent No.
`8,155,012, June 14, 2017
`1037 Dan Blacharski, “Maximum Bandwidth: A Serious Guide to
`High-Speed Networking”, Que Corporation (1997)
`1038 Michael Nootbar, “Why Power Over Signal Pairs?” (March
`2000)
`
`1035
`
`1036
`
`iv
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`
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`IPR2018-01511
`Petitioner’s Reply to Patent Owner’s Preliminary Response
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`Previously
`Submitted
`X
`
`X
`
`X
`
`X
`
`X
`
`X
`
`X
`
`X
`X
`
`
`
`
`
`Exhibit
`No.
`1039 Randy H. Katz “High Performance Network and Channel-
`Based Storage”, Report UCB/CSD 91/650, September 1991
`1040 Robert Muir, “DTE power over MDI - DTE Discovery
`Process Proposal” (November 1999)
`1041 Definitions of “10Base-T” and “100Base-T”, Microsoft
`Computer Dictionary, Microsoft Press 5th ed. 2002
`Standard Microsystems Corp. Data Catalog (1982)
`http://www.bitsavers.org/components/standardMicrosystems/_
`dataBooks/1982_StandardMicrosystems.pdf
`1043 UART Datasheet (2008)
`https://www.nxp.com/docs/en/data-sheet/SCC2691.pdf
`1044 What is a DC-DC converter?
`https://www.rohm.com/electronics-basics/dc-dc-
`converters/what-is-dc-dc-converter
`1045 What is the Difference Between Linear and Switching
`Regulators? https://www.rohm.com/electronics-basics/dc-dc-
`converters/linear-vs-switching-regulators
`1046 Declaration of Matthew B. Shoemake
`1047 Declaration of Michael W. De Vries in Support of Motion to
`Appear Pro Hac Vice on Behalf of Petitioner Cisco Systems,
`Inc.
`1048 Cisco Sys., Inc. et al v. ChriMar Sys., Inc., No. 15-cv-10817,
`Dkt. 1 (E.D. Mich. Mar. 5, 2015)
`1049 Cisco Sys., Inc. et al v. ChriMar Sys., Inc., No. 15-cv-10817,
`Dkt. 16 (E.D. Mich. Feb. 17, 2018)
`
`1042
`
`
`
`Description
`
`v
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`IPR2018-01511
`Petitioner’s Reply to Patent Owner’s Preliminary Response
`
`I.
`
`INTRODUCTION
`The Board should deny ChriMar’s request to dismiss Cisco’s petition.
`
`ChriMar argues that, under 35 U.S.C. § 315(a)(1), Cisco is barred from seeking IPR
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`of U.S. Patent No. 8,902,760 (the “’760 patent”) because Cisco filed and voluntarily
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`dismissed a declaratory-judgment complaint alleging invalidity of the ’760 patent.
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`But Cisco voluntarily dismissed that complaint without prejudice under Rule 41(a)
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`before any substantive activity occurred in that proceeding and before filing its
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`petition. Cisco is not proceeding in both a district court and before the Board, and
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`its prior complaint is not a bar to proceeding here. Under controlling Board
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`precedent, Cisco is not precluded from seeking IPR of the ’760 patent.
`
`ChriMar relies on the Federal Circuit’s decision in Click-To-Call Techs., LP
`
`v. Ingenio, Inc., 899 F.3d 1321 (Fed. Cir. 2018), to argue that the Board should
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`overturn its prior § 315(a)(1) decisions. But as ChriMar concedes, Click-To-Call
`
`interpreted a different statutory provision. (POPR at 2.) Those provisions have very
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`different language and purposes. Click-To-Call’s holding that voluntary dismissal of
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`a patent-infringement complaint under Rule 41(a) does not toll the one-year petition-
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`filing deadline under § 315(b) was based on interpretation of the specific statutory
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`language appearing in 315(b)—“served with a complaint”—which does not appear
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`in 315(a)(1). In contrast to that language, under 315(a)(1), “[a]n [IPR] may not be
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`instituted if, before the date on which the petition for such a review is filed, the
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`1
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`IPR2018-01511
`Petitioner’s Reply to Patent Owner’s Preliminary Response
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`petitioner…filed a civil action challenging the validity of a claim of the patent.”
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`Congress’ decision to tie § 315(a)(1) to filing a civil action, rather than to serving a
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`complaint, indicates that the triggering circumstance for 315(a)(1) is not merely the
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`procedural act of filing a complaint. Had that been the case, Congress would have
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`used the phrase “filed a complaint” in § 315(a).1 Its decision cannot be disregarded.
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`Rather, consistent with the plain meaning of “action” as a “proceeding,” the
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`Board has properly interpreted § 315(a)(1) to require existing substantive litigation
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`in district court over a patent’s validity for the bar to apply. Clio USA, Inc., IPR2013-
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`00438, Paper 9 at 8–9 (P.T.A.B. Jan. 9, 2014) (holding that a voluntarily-dismissed
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`declaratory-judgment action for invalidity did not bar IPR under § 315(a)(1), where
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`the patent owner did not file an answer to the declaratory-judgment complaint).
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`Click-To-Call does not justify ignoring the actual language of § 315(a)(1) or
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`overturning the Board’s settled precedent interpreting it. Indeed, this is consistent
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`with § 315(a)’s legislative history likewise making clear that its purpose is to prevent
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`serial invalidity challenges of the same patents by a party. That concern does not
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`1 “Complaint” and “civil action” are not synonyms. Quite the contrary. Black’s
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`Law Dictionary defines “complaint” as “[t]he initial pleading that starts a civil
`
`action,” whereas “action” is defined as “an ordinary proceeding in a court of
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`justice . . . .” See Black's Law Dictionary (10th ed. 2014).
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`2
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`IPR2018-01511
`Petitioner’s Reply to Patent Owner’s Preliminary Response
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`exist where, as here, a declaratory-judgment complaint was dismissed without
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`prejudice such that no action remains, becoming a nullity as a matter of law.
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`Further, the point of a dismissal without prejudice is to preserve the ability of
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`the plaintiff to sue the defendant again on the same claim. Thus, although Click-To-
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`Call found that this anti-preclusion principle had no application to § 315(b), which
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`is essentially a statute of limitations, it is certainly applicable to § 315(a)(1), which
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`is a preclusion statute. In sum, Cisco’s petition is fully consistent with both the letter
`
`and intent of § 315(a)(1), and the Board should reject ChriMar’s misguided request
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`that the Board overturn settled precedent based on a decision regarding a different
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`statutory provision with different language and a different purpose.
`
`II. BACKGROUND
`On March 5, 2015, Cisco filed a declaratory-judgment complaint in Michigan
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`for non-infringement and invalidity of the ’760 patent. Cisco Sys. v. ChriMar Sys.,
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`15-cv-10817, Dkt. 1 (E.D. Mich.) (Ex. 1048). That never progressed substantively
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`as a civil action. Instead, the Michigan court administratively closed the case for
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`roughly 29 months while the parties awaited substantive rulings from a different
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`district court case over a related patent to the ’760 patent in the Northern District of
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`California. On February 17, 2018, Cisco voluntarily dismissed the Michigan
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`declaratory judgment complaint without prejudice, before there was any substantive
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`litigation on the validity of the ’760 patent, rendering that action a nullity. Id. at Dkt.
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`3
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`IPR2018-01511
`Petitioner’s Reply to Patent Owner’s Preliminary Response
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`16 (Ex. 1049). ChriMar did not file an answer to Cisco’s declaratory-judgment
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`complaint before Cisco dismissed the complaint without prejudice.
`
`III. CLICK-TO-CALL DOES NOT BAR INSTITUTION
`As ChriMar concedes, Click-To-Call does not address 315(a)(1), but is instead
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`narrowly limited to § 315(b). ChriMar nevertheless argues that the Board should
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`extend Click-To-Call to 315(a)(1), so as to preclude IPR whenever a petitioner
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`completed the procedural act of filing a declaratory-judgment complaint for
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`invalidity, even if the action that complaint gave rise to was dismissed before any
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`substantive litigation on the issue of invalidity occurred. But unlike § 315(b), whose
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`bar arises based on service of a complaint, the bar of 315(a)(1) arises based on filing
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`of an action. Accordingly, neither the holding nor logic of Click-To-Call applies to
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`§ 315(a)(1), and the Board should not reconsider its interpretation of § 315(a)(1).
`
`Click-To-Call explicitly focused on the operative phrase of § 315(b), “served
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`with a complaint,” and relied on “[t]he ordinary, contemporary, common meaning”
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`of that phrase in arriving at its conclusion that “§ 315(b)’s time bar is implicated
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`once a party receives notice through official delivery of a complaint in a civil action,
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`irrespective of subsequent events.” Click-To-Call at 1330. But § 315(a)(1) does
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`not have this language, or even mention service of a complaint or any one-year time
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`bar. Despite these differences, ChriMar incorrectly asserts that “[t]he relevant text
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`of § 315(a)(1) parallels that of § 315(b).” POPR at 3. But no such parallel exists
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`4
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`IPR2018-01511
`Petitioner’s Reply to Patent Owner’s Preliminary Response
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`and ChriMar’s contrary suggestion leaves no doubt its argument is incorrect.
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`First and foremost, Congress purposely focuses on the “civil action,” and not
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`procedural service of a complaint, in § 315(a)(1). Had Congress wanted the
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`preclusive effect of § 315(a)(1) to be triggered by the mere filing of a complaint—
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`regardless of whether any actual litigation on the issue of invalidity ensued—it
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`would have used the words “files a complaint,” as it did in § 315(b) with respect to
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`“service of a complaint.” Instead, § 315(a)(1)’s use of the different term “civil
`
`action” indicates a different intent on the part of Congress. See, e.g., RaceTires Am.,
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`Inc. v. Hoosier Racing Tire Corp., 674 F.3d 158, 165 (3d Cir. 2012) (“It is a well-
`
`established canon of statutory interpretation that the use of different words or terms
`
`within a statute demonstrates that Congress intended to convey a different meaning
`
`for those words.”).
`
`Moreover, the legislative history confirms the importance of the actual
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`language—“civil action”—that Congress selected for § 315(a)(1) in comparison to
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`§ 315(b): the clear purpose of the former is coordination of IPR with litigation, and
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`more specifically to prevent a challenger from getting two bites at the invalidity
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`apple, one in a district court “civil action” and a second before the Board:
`
`The 2009 Minority Report also recommended that the bill restrict
`serial administrative challenges to patents and require coordination of
`these proceedings with litigation. . . . The present bill does coordinate
`inter partes and post-grant review with litigation, barring use of these
`proceedings if the challenger seeks a declaratory judgment that a patent
`is invalid . . . .
`
`5
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`IPR2018-01511
`Petitioner’s Reply to Patent Owner’s Preliminary Response
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`157 Cong. Rec. S1023 at S1041 (March 1, 2011). Thus, consistent with that fact
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`that “action” refers to a “proceeding,” as described above, § 315(a)(1)’s reference to
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`“civil action” is properly interpreted to require the pendency of a litigation where
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`the petitioner actually had a bite at the apple. But here, Cisco and ChriMar never
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`engaged in any litigation over the validity of the ’760 patent. Instead, Cisco
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`voluntarily dismissed its complaint before any substantive activity took place.
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`ChriMar never even answered the declaratory-judgment complaint before it was
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`dismissed without prejudice. Cisco is therefore not seeking the proverbial second
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`bite at the apple that § 315(a)(1) is designed to address, and ChriMar is not engaged
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`in multiple proceedings over the patent requiring any coordination.
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`Second, § 315(a)(1) uses the term “filed,” while § 315(b) uses the term
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`“served.” Filing and service are obviously not the same, and it is well-settled that
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`the voluntary dismissal of a complaint without prejudice nullifies the act of filing.
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`See, e.g., 9 Wright & Miller, Federal Prac. and Proc. § 2367 (3d. ed. 2018) (“[A]s
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`numerous federal courts have made clear, a voluntary dismissal without prejudice .
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`. . leaves the situation as if the action never had been filed.”). Indeed, even in Click-
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`To-Call, the Federal Circuit recognized that dismissal of an action without prejudice
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`leaves the action as if it had never been filed for at least certain purposes. See Click-
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`To-Call at 1334–36. In particular, in the case of a voluntary dismissal without
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`prejudice, issue and claim preclusion do not apply to later actions. “[T]he point of
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`6
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`IPR2018-01511
`Petitioner’s Reply to Patent Owner’s Preliminary Response
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`a dismissal ‘without prejudice’ is to preserve, rather than eliminate, the ability of the
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`plaintiff to sue the defendant again on the same claim.” Click-To-Call at 1348
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`(Taranto, C.J., concurring). Thus, although Click-To-Call found that this anti-
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`preclusion principle had no application to § 315(b), which is essentially a statute of
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`limitations, it is certainly applicable to § 315(a)(1), which is a preclusion statute.
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`For this reason, the Board has routinely recognized that a petitioner can elect
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`to “unmake” its choice to file a declaratory-judgement action through a voluntary
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`dismissal without prejudice, without being subjected to claim or issue preclusion.
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`See Clio USA, Inc., IPR2013-00438, Paper 9 at 8 (“[W]hen a court permits the
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`challenger to dismiss the declaratory judgment action voluntarily and without
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`prejudice, the petitioner effectively unmakes that choice, because the action is
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`considered never to have existed”). Dismissal without prejudice of a claim
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`challenging the validity of a patent preserves, and does not eliminate, the ability of
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`an accused infringer to challenge a patent before the Board rather than in district
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`court. Therefore, the Federal Circuit’s reasoning in Click-To-Call simply cannot and
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`should not be extended to § 315(a), and the Board should not reconsider its long-
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`standing interpretation of that statute.
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`IV. CONCLUSION
`For the foregoing reasons, Cisco respectfully request that the Board institute
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`Cisco’s Petition for IPR of the ’760 patent.
`
`7
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`IPR2018-01511
`Petitioner’s Reply to Patent Owner’s Preliminary Response
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`Date: December 28, 2018
`
`
`
`
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`Respectfully submitted,
`
`/s/ James Marina
`James Marina (Reg. No. 41,969)
`KIRKLAND & ELLIS LLP
`601 Lexington Avenue
`New York, NY 10022
`Telephone: (212) 446-4800
`Fax: (212) 446-4900
`james.marina@kirkland.com
`
`Robert Kang (Reg. No. 59,609)
`KIRKLAND & ELLIS LLP
`555 California Street
`San Francisco, CA 94104
`Telephone: (415) 439-1400
`Fax: (415) 439-1500
`robert.kang@kirkland.com
`
`Eugene Goryunov (Reg. No. 61,579)
`KIRKLAND & ELLIS LLP
`300 North LaSalle
`Chicago, IL 60654
`Telephone: (312) 862-2000
`Fax: (312) 862-2200
`eugene.goryunov@kirkland.com
`
`Attorneys For Petitioner Cisco
`Systems, Inc.
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`8
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`IPR2018-01511
`Petitioner’s Reply to Patent Owner’s Preliminary Response
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a copy of the foregoing is being served
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`on December 28, 2018, via email directed to counsel of record for the Patent Owner
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`at the following:
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`
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`CHRMC0121IPR@brookskushman.com
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`/s/ James Marina
`James Marina
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`
`9
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