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`Paper No. 2
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________
`
`
`PRICELINE.COM LLC AND BOOKING.COM B.V.
`Petitioners
`
`
`v.
`
`
`DDR HOLDINGS, LLC
`Patent Owner
`
`______________
`
`
`
`
`U.S. Patent 9,639,876
`
`
`______________
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`
`
`
`PETITIONERS’ MOTION FOR JOINDER
`UNDER 35 U.S.C. 315(c) AND 37 C.F.R. §§ 42.22 AND 42.122(b)
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`
`73750411.1
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`
`
`TABLE OF AUTHORITIES
`
` Page(s)
`
`Cases
`Amerigen Pharm Ltd, v. UCB Pharma GMBH,
`IPR2016-01665, Paper 8 (PTAB Dec. 7, 2016) ................................................. 11
`Celltrion, Inc., v. Genentech, Inc.,
`IPR2018-01019, Paper 11 (PTAB Oct. 30, 2018) .................................. 2, 3, 8, 12
`Dell Inc. v. Network-1 Security Solutions, Inc.,
`IPR2013-00385 ..................................................................................................... 4
`Dell Inc. v. Network-1 Solutions, Inc.,
`IPR2013-00385, Paper 17 (PTAB July 29, 2013) ................................................ 9
`Enzymotec Ltd. v. Neptune Techs & Bioresources, Inc.,
`IPR2014-00556 ..................................................................................................... 5
`Hyundai Motor Co. v. Am Vehicular Scis. LLC,
`IPR2014-01543, Paper 11 (PTAB Oct. 24, 2014) ................................................ 8
`Microsoft Corp. v. Proxyconn Inc.,
`IPR2013-00109, Paper 15 (PTAB Feb. 25, 2013) ................................................ 5
`Motorola Mobility,
`IPR2013-00256, Paper 10 (PTAB June 20, 2013) ............................................... 9
`Oracle America, Inc. v. Realtime Data LLC,
`IPR2016-01672, Paper 13 (PTAB Mar. 7, 2017) ............................................. 7, 8
`Shopify, Inc.,
`Case IPR2018-01011 ..............................................................1, 4, 5, 6, 7, 8, 9, 12
`Sony Corp. of Am. v. Network-1 Sec Solutions, Inc.,
`IPR2013-00495, Paper 13 (PTAB Sept. 16, 2013) ............................................... 8
`Teva Pharmaceuticals USA, Inc., v. Allergan, Inc.,
`IPR2017-00579, Paper 9 (PTAB March 31, 2017) .............................................. 5
`Torrent Pharm Ltd, v. UCB Pharma GMBH,
`IPR2016-01636, Paper 10 (PTAB Dec. 7, 2016) ............................................... 11
`-i-
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`73750411.1
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`Rules and Statutes
`35 U.S.C. § 102(a) ..................................................................................................... 3
`35 U.S.C. § 103(a) ..................................................................................................... 3
`35 U.S.C. § 315(b) ..................................................................................................... 5
`35 U.S.C. § 315(c) ................................................................................................. 1, 4
`Other Authorities
`37 C.F.R. § 42.22 ....................................................................................................... 1
`37 C.F.R. § 42.122(a) ................................................................................................. 4
`37 C.F.R. § 42.122(b) ........................................................................................ 1, 4, 5
`157 CONG. REC. S1376 (daily ed. Mar. 8, 2011) (statement of Sen.
`Kyl) ....................................................................................................................... 5
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`73750411.1
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`-ii-
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`I.
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`STATEMENT OF THE PRECISE RELIEF REQUESTED
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`Priceline.com LLC and Booking.com B.V. (“Petitioners”) respectfully
`
`submit this Motion for Joinder together with a Petition for Inter Partes Review of
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`U.S. Patent No. 9,639,876 (the “’876 Patent”). Petitioners respectfully request
`
`their Petition for Inter Partes Review be granted and joined pursuant to 35 U.S.C.
`
`§ 315(c) and 37 C.F.R. §§ 42.22 and 42.122(b) with the petition for inter partes
`
`review (the “Shopify Petition”) filed by Shopify, Inc. concerning the ’876 Patent:
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`Shopify, Inc. v. DDR Holdings, LLC, IPR2018-01011 (the “’011 IPR”), in which
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`trial was instituted on Grounds 1, 2, 3, and 4 on November 15, 2018. Petitioners’
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`Motion for Joinder and accompanying Petition are being filed within one month of
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`the decision instituting trial in the ’011 IPR, and are therefore timely. 37 C.F.R. §
`
`42.122(b)
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`Petitioners’ Petition relies on the references cited and follows the arguments
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`raised in the Shopify Petition, and is substantively identical to the Shopify Petition.
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`The present Petition includes identical grounds as those presented in the Shopify
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`Petition and therefore would create no additional burden for the Board, Shopify, or
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`Patent Owner if joined. Joinder would therefore lead to an efficient resolution of
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`the validity of the ’876 Patent.
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`Counsel for Petitioners and counsel for Shopify met and conferred as to the
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`level of cooperation between Shopify and Petitioners that will be maintained if
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`73750411.1
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`Petitioners’ motion for joinder is granted. Petitioners stipulate that if joinder is
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`granted, Petitioners will cooperate with Shopify in the joined proceeding, whether
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`at hearings, at depositions, in filings, or otherwise, as outlined below. Unless
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`Shopify is terminated from the proceedings, Petitioners will proceed in a limited
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`“understudy” role. Joinder will not impact the trial schedule because the
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`proceeding based on the Shopify Petition is in its early stages.
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`The Board has granted joinder in other proceedings when presented with the
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`fact pattern described herein. For example, the Board recently joined Celltrion,
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`Inc. to an instituted IPR where Pfizer, Inc. was the Petitioner. Celltrion, Inc., v.
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`Genentech, Inc., IPR2018-01019, Paper 11, (PTAB Oct. 30, 2018). In that case,
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`Pfizer had previously filed a petition for inter partes review of the patent at issue,
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`and its petition had been instituted. Subsequently, Celltrion filed a petition with a
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`Motion for Joinder to Pfizer’s IPR2017-01923. Pfizer and Celltrion had agreed
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`that Celltrion would take an understudy role to Pfizer and no deadlines in the
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`original IPR were changed. Further, Celltrion agreed to not rely on expert
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`testimony provided in support of Celltrion’s IPR petition unless Pfizer was
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`terminated from the proceeding before Pfizer’s expert was deposed. The Board
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`granted joinder, finding that doing so did not increase the burden on either the
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`patent owner or the Board.
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`Here, Petitioners and Shopify have agreed to a similar arrangement, with
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`73750411.1
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`Shopify taking the lead role and Petitioners taking the understudy role. Further,
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`Petitioners will not rely on the declaration of Peter Kent (which is substantively the
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`same as Shopify’s expert declaration) submitted with the present petition, unless
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`Shopify is terminated from the proceeding prior to the Shopify expert being
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`deposed. Under these circumstances, which are materially similar to those in
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`IPR2018-01019, there is no undue prejudice to Patent Owner, and therefore the
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`Board should institute IPR and grant Petitioners’ Motion for Joinder. See id. at 14-
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`15.
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`II.
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`STATEMENT OF MATERIAL FACTS
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`1.
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`On May 3, 2017, Petitioners were served with a complaint by Patent
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`Owner asserting Petitioners infringed claims of the ’876 Patent.
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`2.
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`Petitioners previously filed IPR2018-0482 involving U.S. Patent No.
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`7,818,399, which is related to the ’876 Patent.
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`3.
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`The Shopify Petition was filed on May 2, 2018, and included the
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`following grounds of challenge: Ground 1, claims 1-5, 7, 8, 11-15, 17, and 18 of
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`the ’876 Patent are invalid under 35 U.S.C. § 103(a) over the Digital River
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`Publications; Ground 2, claims 1-5, 7, 8, 11-15, 17, and 18 of the ’876 Patent are
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`invalid under 35 U.S.C. § 102(a) over Moore; Ground 3, claims 1, 7, 11, and 17 of
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`the ’876 Patent are invalid under 35 U.S.C. § 103(a) over Moore and Arnold; and
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`Ground 4, claims 1-5, 7, 8, 11-15, 17, and 18 of the ’876 Patent are invalid over
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`73750411.1
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`Moore and the Digital River Publications.
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`4.
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`Patent Owner filed a Preliminary Patent Owner’s Response to the
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`Shopify Petition on August 21, 2018.
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`5.
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`On November 15, 2018, a decision instituting trial on Grounds 1, 2, 3,
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`and 4 of the Shopify Petition was entered in IPR2018-01011.
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`III. STATEMENT OF REASONS FOR REQUESTED RELIEF
`A. Legal Standard
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`The Leahy-Smith America Invents Act (AIA) permits joinder of like
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`proceedings, e.g. an inter partes review may be joined with another inter partes
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`review. 37 C.F.R. § 42.122(a). The Board has discretion to join parties to an
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`existing inter partes review. 35 U.S.C. § 315(c). In deciding whether to exercise
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`its discretion, the Board considers factors including: (1) the movant’s reasons why
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`joinder is appropriate; (2) whether the new petition presents any new grounds of
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`unpatentability; (3) what impact (if any) joinder would have on the trial schedule
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`for the existing review; and (4) how briefing and discovery may be simplified.
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`Dell Inc. v. Network-1 Security Solutions, Inc., IPR2013-00385, Paper No. 17 at 4
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`(July 29, 2013).
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`B.
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`Petitioners’ Motion for Joinder is Timely
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`The instant Petition and this Motion for Joinder are timely under 35 U.S.C. §
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`315(c) and 37 C.F.R. § 42.122(b). While, as a general proposition, a petition for
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`73750411.1
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`inter partes review may not be filed more than one year after the date on which a
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`petitioner is served with a complaint alleging infringement of the patent-at-issue
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`(35 U.S.C. § 315(b)), the one year period does not apply when a petition for inter
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`partes review is accompanied by a motion for joinder filed within one month of
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`institution of the inter partes review for which joinder is requested. 37 C.F.R. §
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`42.122(b); Microsoft Corp. v. Proxyconn Inc., IPR2013-00109, Paper 15 at 4-5
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`(PTAB Feb. 25, 2013); Teva Pharmaceuticals USA, Inc., v. Allergan, Inc.,
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`IPR2017-00579, Paper 9 at 4-5 (PTAB March 31, 2017). This Motion for Joinder
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`and the accompanying Petition are timely, as they are submitted within one month
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`of the institution of trial on the Shopify Petition in the ’011 IPR.
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`C.
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`Joinder Will Promote an Efficient Determination of the Validity
`of the Challenged Claims of the ’876 Patent Without Prejudice to
`Any Party
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`The PTAB has previously stated that it is “mindful of a policy preference for
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`joining a party that does not present new issues that might complicate or delay an
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`existing proceeding.” Enzymotec Ltd. v. Neptune Techs & Bioresources, Inc.,
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`IPR2014-00556, Paper No. 19 at 6 (July 9, 2014) (citing 157 CONG. REC. S1376
`
`(daily ed. Mar. 8, 2011) (statement of Sen. Kyl) (“The Office anticipates that
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`joinder will be allowed as of right – if an inter partes review is instituted on the
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`basis of a petition, for example, a party that files an identical petition will be joined
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`to that proceeding, and thus allowed to file its own briefs and make its own
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`73750411.1
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`arguments.”)). If Petitioners are joined as a party, the validity of the grounds
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`raised in the Shopify Petition and Petitioners’ Petition can be determined in a
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`single proceeding.
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`Petitioners’ Petition challenges the same claims of the ’876 Patent on the
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`same grounds upon which trial in the ’011 IPR was instituted and relies on the
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`same legal theories relied on by the Shopify Petition. There are no substantive
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`differences between Petitioners’ Petition and the Shopify Petition.1 See Shopify,
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`1 It is unclear whether recent rule changes implementing a plain and ordinary
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`meaning claim construction standard for IPRs apply to joinder. Regardless,
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`Petitioners believe the construction positions taken by Shopify, Patent Owner, and
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`the Board in the ’011 IPR and/or other proceedings related to this patent family are
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`consistent with constructions that were previously applied in Federal Court to other
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`claims in the family of patents at issue under the plain and ordinary meaning
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`standard. Petitioners submit that the outcome of the ’011 IPR will not be changed
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`based on which claim construction standard is applied and therefore this rule
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`change will not burden the present case. Further, institution and joinder of the
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`Petition with the ’011 IPR will not prejudice Patent Owner in any way as the ’011
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`IPR has already been instituted under the broadest reasonable interpretation
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`standard and using a plain and ordinary meaning standard would not adversely
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`impact Patent Owner.
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`73750411.1
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`IPR2018-01011, Paper 8 (Aug. 21, 2018).
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`Petitioners also rely on substantially the same supporting evidence in their
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`Petition as is relied on in the Shopify Petition.2 A consolidated proceeding,
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`including both Shopify and Petitioners, will therefore be efficient as only a single
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`trial on these common grounds would be required. See, e.g., Oracle America, Inc.
`
`v. Realtime Data LLC, IPR2016-01672, Paper 13 at 7 (PTAB Mar. 7, 2017)
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`(noting that “joining Oracle’s identical challenges to those in the 1002 IPR will
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`lead to greater efficiency while reducing the resources necessary from both
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`Realtime and the Board”).
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`Joining Petitioners as a party to the ’011 IPR also would not cause any
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`prejudice to either Patent Owner or Shopify. Patent Owner must respond to the
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`common invalidity grounds identified in the Shopify Petition and Petitioners’
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`2 In support of their Petition, Petitioners have also submitted the Declaration of Mr.
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`Peter Kent (the “Kent Declaration”). The Kent Declaration is substantively identi-
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`cal to the Declaration of Michael Shamos (the “Shamos Declaration”) filed in sup-
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`port of the Shopify Petition, but differs from the Shamos Declaration in that it has
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`been updated to list the qualifications and personal experience of Mr. Kent. Mr.
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`Kent’s discussion of the prior art and the analysis of the prior art as applied to the
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`challenged claims is substantively the same as the discussion and analysis set forth
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`in the Shamos Declaration.
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`73750411.1
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`Petition and will be exposed to taking a deposition of a single expert regardless of
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`joinder. Thus, Patent Owner bears no additional burden. For both Patent Owner
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`and Shopify, Petitioners’ Petition has been filed sufficiently early so that joinder
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`would affect neither the potential schedule of the inter partes review, nor the costs
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`associated with a full trial. See id.
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`This factor favors joinder.
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`D.
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`Petitioners’ Petition Does Not Raise Any New Grounds of
`Unpatentability and Therefore Does Not Add Additional
`Complexity to the Grounds in the Shopify Petition
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`Petitioners’ Petition challenges the validity of identical claims of the ’876
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`Patent on identical grounds to those in the Shopify Petition. See Shopify, IPR2018-
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`01011, Paper 8 (Aug. 21, 2018). Petitioners’ supporting materials, including the
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`supporting expert declaration, are also substantially the same as those presented by
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`Shopify. See, supra, n. 2. Therefore, consolidation of this proceeding with the
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`’011 IPR via joinder of Petitioners’ Petition will not raise any new issues of
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`unpatentability and will not impose any additional burden on the Board or add
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`additional complexity to the case. The Board has granted joinder in similar
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`situations. See, e.g., Celltrion, Inc., v. Genetech, Inc., IPR2018-01019, Paper 11 at
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`14-15 (PTAB Oct. 30,2018); Hyundai Motor Co. v. Am Vehicular Scis. LLC,
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`IPR2014-01543, Paper 11 at 2-4 (PTAB Oct. 24, 2014); Sony Corp. of Am. v.
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`Network-1 Sec Solutions, Inc., IPR2013-00495, Paper 13 at 5-9 (PTAB Sept. 16,
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`73750411.1
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`2013); Dell Inc. v. Network-1 Solutions, Inc., IPR2013-00385, Paper 17 at 6-10
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`(PTAB July 29, 2013); Motorola Mobility, IPR2013-00256, Paper 10 at 4-10
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`(PTAB June 20, 2013).
`
`This factor favors joinder.
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`E.
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`Joinder Would Not Affect the Schedule of the ’011 IPR
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`Given that the Board instituted review of the Shopify Petition less than one
`
`month ago, joinder of Petitioners would not affect the schedule in any forthcoming
`
`trial. Petitioners’ participation would result in no changes to the scheduling order
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`issued November 15, 2018, in the ’011 IPR.
`
`This factor favors joinder.
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`F.
`
`Joinder Will Simplify Briefing and Discovery Because Petitioners
`Have Agreed to Consolidated Filings and an Understudy Role
`
`To further prevent joinder from imposing any burden on Patent Owner or
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`Shopify and to further ensure that there are no changes in the potential trial
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`schedule, Petitioners have agreed, as long as Shopify remains a party to the ’011
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`IPR proceeding, to (1) coordinate any communications with Shopify’s experts
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`through Shopify’s counsel; (2) not produce their own testifying witnesses; and (3)
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`not file substantive papers (except for those associated with Board-approved
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`motions that do not affect Shopify or Shopify’s position).
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`Petitioners also will confer and cooperate with Shopify on the consolidated
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`filings but, as long as Shopify is a party, Shopify will make all final decisions and
`-9-
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`73750411.1
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`will retain responsibility for oral argument (including telephone hearings and
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`appeals). Petitioners will not seek or receive separate time and will not separately
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`argue during oral argument, including telephone hearings and appeals, except
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`when addressing Board-approved motions that do not affect Shopify or Shopify’s
`
`position.
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`Petitioners also will coordinate the discovery and testimony relating to
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`witnesses with Shopify but, as long as Shopify is a party, Shopify will make all
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`final decisions. In particular, as long as Shopify is a party, Petitioners will not
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`separately file or serve objections or discovery requests, will not receive separate
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`cross examination or redirect time, will not separately cross examine or redirect
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`any witness, and agree that cross examinations will occur within the time frame
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`normally allotted to one party without a need for extension in light of the joinder.
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`Thus, for briefing and document submissions, as long as Shopify remains a
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`party to the inter partes review, the Board may order petitioners to consolidate
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`filings such that Shopify would submit papers on behalf of petitioners and
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`Petitioners would not be allowed additional filings. Moreover, for depositions, no
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`adjustments to the schedule would be required and, indeed, no additional
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`depositions would be necessary. Petitioners will not rely on expert testimony
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`beyond that submitted by Shopify unless Shopify is terminated from the case prior
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`to any necessary depositions. Thus, Petitioners’ expert, Mr. Kent, would not be
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`73750411.1
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`-10-
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`relied on if Shopify’s expert remains available through relevant deposition periods.
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`However, if Shopify is no longer a party, Petitioners will be free to rely on the
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`opinions and testimony of Mr. Kent, and other declarants for Shopify that are
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`already of record. Further, the opinions and testimony of Mr. Kent are
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`substantively the same as the opinions and testimony of Shopify’s expert.
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`Therefore, if Shopify is terminated from the proceedings and Shopify’s expert is
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`not available prior to Patent Owner deposing Shopify’s expert, the deposition of
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`Petitioners’ expert would cover substantially identical materials, opinions, and
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`legal theories as would be addressed by Patent Owner were Shopify’s expert to be
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`deposed. Consequently, no additional expert discovery will be required if joinder
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`is allowed, thereby simplifying discovery.
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`As a result of the foregoing, by consolidating filings with Shopify, Patent
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`Owner will only need to respond to one principal set of papers. No further time to
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`address additional arguments will be required by any party, and the consolidated
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`trial can thus proceed at the same pace as if Petitioners were not joined. Torrent
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`Pharm Ltd, v. UCB Pharma GMBH, IPR2016-01636, Paper 10 at 5 (PTAB Dec. 7,
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`2016); Amerigen Pharm Ltd, v. UCB Pharma GMBH, IPR2016-01665, Paper 8 at
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`6 (PTAB Dec. 7, 2016).
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`This factor favors joinder.
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`G. The Board Has Granted Joinder Under These Circumstances,
`Finding No Undue Burden or Prejudice
`-11-
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`73750411.1
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`As discussed above, the Board has granted joinder in IPR2018-01019, with
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`facts similar to those here. In that case, Pfizer and Celltrion agreed that Celltrion
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`would take an understudy role to Pfizer and no deadlines in the original IPR were
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`changed using the same expert stipulations described above. The Board granted
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`joinder, finding that joinder neither placed undue burden on nor caused undue
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`prejudice to the patent owner. See Celltrion, Inc., v. Genetech, Inc., IPR2018-
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`01019, Paper 11 at 14-15 (PTAB Oct. 30,2018). The circumstances are similar
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`here, and therefore the Board should institute IPR and grant Petitioners’ Motion for
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`Joinder.
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`IV. CONCLUSION
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`For the foregoing reasons, Petitioners respectfully request that the Board
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`institute their Petition for Inter Partes Review of U.S. Patent No. 9,639,876 and
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`join the proceeding with Shopify, Inc., Case IPR2018-01011. Although it is
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`believed that no fee is required for this Motion, the Commissioner is hereby
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`authorized to charge any fees that may be required for this Motion to Deposit
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`Account 06-2380.
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`73750411.1
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`Dated: December 14, 2018
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`Respectfully submitted,
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`~-:===s
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`Nathan J. Rees (Reg. No. 63,820)
`NORTON ROSE FULBRIGHT US LLP
`2200 Ross Avenue, Suite 3600
`Dallas, Texas 75201-7932
`Tel: 214.855.7164
`Fax: 214.855.8200
`nate.rees@nortonrosefulbright.com
`Attorney for Petitioners
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`737504 11.1
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`-1 3-
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`Certificate of Service
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`Pursuant to 37 C.F.R. § 42.6(e) and 37 C.F.R. § 42.105(a), the undersigned
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`certifies that on December 14, 2018, a complete copy of Petitioners' Motion for
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`Joinder Under 35 U.S.C. 315(c) and 37 C.F.R. §§ 42.22 and 42.122(b) ("Motion")
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`was served via Federal Express on the following counsel for the Patent Owner:
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`Lead Counsel for DDR Holdings, LLC
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`Back Up Counsel for DDR Holdings,
`LLC
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`Louis J. Hoffman (Reg. No. 38,918)
`Louis J. Hoffman, P.C.
`7689 East Paradise Lane, Suite 2
`Scottsdale, Arizona 85260
`Telephone: (480) 948-3295
`Emails: louis@valuablepatents.com;
`DDR_IPR@valuablepatents.com
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`Justin J. Lesko (Reg. No. 69,643)
`Louis J. Hoffman, P.C.
`7689 East Paradise Lane, Suite 2
`Scottsdale, Arizona 85260
`Telephone: ( 480) 948-3295
`Emai l: justinlesko@patentit.com
`
`Attorney for Petitioners
`Registration No. 63 ,820
`
`2200 Ross Avenue, Suite 3600
`Dallas, Texas 75201 -7932
`(214) 855-7164
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`737504 I I. I
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