UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`ARKEMA AND ARKEMA FRANCE
`Petitioner,
`v.
`
`HONEYWELL INTERNATIONAL INC.,
`Patent Owner.
`
`
`
`Case No.: PGR2016-00011
`Patent No.: 9,157,017
`
`
`PATENT OWNER’S OPPOSITION TO PETITIONER’S
`
`MOTION TO EXCLUDE UNDER 37 C.F.R. § 42.64(C)
`
`
`
`
`
`
`
`
`
`
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`ARKEMA AND ARKEMA FRANCE
`Petitioner,
`v.
`
`HONEYWELL INTERNATIONAL INC.,
`Patent Owner.
`
`
`
`Case No.: PGR2016-00011
`Patent No.: 9,157,017
`
`
`PATENT OWNER’S OPPOSITION TO PETITIONER’S
`
`MOTION TO EXCLUDE UNDER 37 C.F.R. § 42.64(C)
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Honeywell opposes Arkema’s motion to exclude Exhibits 2101, 2102, and
`
`2103, all of which are documents (specifically, declarations) previously filed with
`
`the Patent Office during prosecution of the ‘017 patent and which are relied upon
`
`by Honeywell’s experts. Arkema points to no case in which the PTAB has
`
`excluded portions of the file history of the challenged patent. Rather, Arkema
`
`contends, without legal support, that Exhibits 2101, 2102, and 2103 are hearsay.
`
`Arkema, again without legal support, also contends that the PTAB should exclude
`
`portions of Exhibit 1057, a document Arkema itself introduced into the record of
`
`this proceeding, because Arkema did “not cite or otherwise rely on” those portions.
`
`Paper 36 at 6.
`
`Arkema’s complaint about these documents is its claimed failure to cross-
`
`examine the authors, Richard Winick and Raymond Thomas. Yet Arkema fails to
`
`mention that it deposed Dr. Thomas—in addition to a host of other Honeywell
`
`employees and experts—in a prior litigation between Arkema and Honeywell
`
`concerning the ‘366 patent, a parent to the ‘017 patent. Indeed, Exhibit 2103
`
`contains the same data presented in a declaration by Rajiv Singh—an inventor of
`
`the ‘017 and ‘366 patents—during prosecution of the ‘366 patent. And Arkema
`
`already cross-examined Dr. Singh concerning that prior declaration. Arkema
`
`cannot credibly claim “prejudice” now where it already had opportunities to
`
`
`
`
`2
`
`
`
`
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`depose multiple Honeywell employees about data which Arkema itself injected
`
`into the record.
`
`I.
`
`BACKGROUND
`
`Arkema moves to exclude Exhibits 2101, 2102, and 2103, all of which are
`
`part of the prosecution history of the ’017 patent (at issue here) and were relied
`
`upon by Honeywell’s experts in this proceeding.
`
` Exhibits 2101 and 2102 are declarations from Richard Winick,
`
`Honeywell’s Global Director of Sales for the Fluorine Products
`
`business.
`
` Exhibit 2103 is a declaration from Dr. Raymond Thomas, a named
`
`inventor on U.S. Pat. Nos. 7,534,366 (“the ‘366 patent”) and
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`8,065,882 (“the ‘882 patent).
`
`The ‘017 patent claims priority to the ‘366 patent. Exhibits 2101, 2102, and
`
`2103 were originally filed in reexaminations of the ‘366 patent (Exs. 2101 and
`
`2103) and ‘882 patent (Ex. 2102). They were also submitted during prosecution of
`
`the ’017 patent.
`
`Exhibit 2101, which deals generally with commercial success, supports
`
`“Honeywell[’s] expect[ation] that, between 2012 and 2017, it will have delivered
`
`over 20 million pounds of HFO-1234yf to customers.” PO Response at 16 (citing
`
`Ex. 2126 ¶ 173; Ex. 2101 at 3); see also PO Response at 83; Ex. 2126 ¶ 173. Dr.
`
`
`
`
`3
`
`
`
`
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`Bivens relies on this statement to conclude that Honeywell was expected to sell $1
`
`billion worth of HFO-1234yf in those five years. Ex. 2126 ¶ 173. Exhibit 2102,
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`which also deals with commercial success, is cited to support the statement that
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`“Honeywell’s customers of HFO-1234yf include General Motors and six other
`
`major automobile manufacturers.” Ex. 2126 ¶ 173 (citing Ex. 2102). Dr. Bivens
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`was subject to cross-examination on his declaration and Arkema had a chance to
`
`question him about his reliance on Exs. 2101 and 2102. They chose not to do so.
`
`Exhibit 2103 discusses miscibility and stability of HFOs with PAGs. It is
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`substantially identical to Exhibit 1057 (introduced by Arkema), a declaration from
`
`Dr. Thomas initially filed in the reexamination of U.S. Pat. No. 8,033,120 (“the
`
`‘120 patent”) and submitted during prosecution of the ‘017 patent. Dr. Bivens cites
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`Exhibit 2103 to demonstrate that “HFO-1234yf and PAG lubricants are miscible at
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`all lubricant concentrations below about 25°C.” Ex. 2126 ¶ 184 (citing Ex. 2103 ¶
`
`20). Paragraph 20 of Exhibit 2103 is substantially identical to paragraph 27 of
`
`Exhibit 1057. Dr. DesMarteau also cites Exhibit 2103 simply to explain how Dr.
`
`Thomas’ testing was conducted. See Ex. 2161 ¶ 55 (citing Ex. 2103 at 6-7); ¶ 58
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`(citing Ex. 2103 at 7). Pages 6-7 of Exhibit 2103 are substantially identical to
`
`paragraphs 28-33 of Exhibit 1057. Dr. Bivens was subject to cross-examination on
`
`his declaration and Arkema had a chance to question him about his reliance on Ex.
`
`2103. They chose not to do so.
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`
`
`
`4
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`
`
`
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`Table 3 of Exhibit 2103, also in Exhibits 1057 and 1180, reports the results
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`of stability testing of HFO-1234yf with a PAG lubricant. Honeywell did not cite
`
`Table 3 of Exhibit 2103, but rather cited Table 3 of Exhibit 1057, which Arkema
`
`introduced.1 Dr. DesMarteau relies on Table 3’s data in Exhibit 1057 for his
`
`opinion that HFO-1234yf has “unexpectedly superior stability” with a PAG
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`lubricant compared to other HFOs. Ex. 2161 ¶ 63. Dr. DesMarteau was subject to
`
`cross-examination on his declaration and Arkema questioned him extensively
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`about his reliance on Ex. 2103. See Ex. 1178 at 57:3-62:21.
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`Additionally, the information in Table 3 was also the subject of a declaration
`
`by Dr. Rajiv Singh submitted during prosecution of the ‘366 patent. See Ex. 2165
`
`at 4 (Table 2). During litigation in the Eastern District of Pennsylvania between
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`Arkema and Honeywell, Civ. A. No. 2:10-cv-2886, Arkema deposed Dr. Singh,
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`cross-examining him regarding the data presented in his declaration. Ex. 2166 at
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`331:2-332:13, 359:21-371:15.
`
`
`1 Although Arkema moves to exclude portions of Exhibit 1057, it does not seek
`
`to exclude Exhibit 1180—also introduced by Arkema—which contains Table 3
`
`at page 24.
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`
`
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`5
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`
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`II. ARGUMENT
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`A. Exhibits 2101-2103 Are Admissible Under Fed. R. Evid. 703
`
`Honeywell’s declarants relied on Exhibits 2101-2103 in this proceeding.
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`Those exhibits are thus admissible under Fed. R. Evid. 703, which allows experts
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`to rely on facts or data even if they would otherwise be inadmissible. While Rule
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`703 requires that any otherwise inadmissible underlying facts or data not be
`
`disclosed to the jury, the portions of the Federal Rules of Evidence concerning
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`juries do not apply here. 37 C.F.R. § 42.62(b). Relying on this provision, the Board
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`has previously held Rule 703’s “jury” caveat inapplicable, holding evidence relied
`
`on by an expert to be admissible via Rule 703. See Nestle Healthcare Nutrition,
`
`Inc. v. Steuben Foods, Inc., IPR2015-00249, Paper 76 at 13 (P.T.A.B. June 2,
`
`2016) (concluding that a deposition, taken outside of the proceeding at issue but
`
`relied upon by an expert in that proceeding, was admissible under Rule 703,
`
`reasoning: “Fed. R. Evid. 703 includes the caveat that if the underlying facts are
`
`inadmissible, those facts may only be disclosed to the jury if their probative value
`
`in helping evaluate the opinion substantially outweighs their prejudicial effect. Our
`
`determination is not made by a jury, so this caveat does not apply.”); First Quality
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`Baby Prod., LLC v. Kimberly-Clark Worldwide, Inc., IPR2014-01023, Paper 56 at
`
`37 (P.T.A.B. Dec. 10, 2015) (based on Rule 703, denying a motion to exclude
`
`evidence relied upon by expert); Funai Electric Co., Ltd., Samsung Display Co.,
`
`
`
`
`6
`
`
`
`
`
`Ltd., and Toshiba Corp. v. Gold Charm Ltd., IPR2015-01468, Paper 40 at 51-53
`
`(P.T.A.B. Dec. 27, 2016) (same); Phigenix, Inc. v. Immunogen, Inc., IPR2014-
`
`00676, Paper 39 at 26-29 (P.T.A.B. Oct. 27, 2015) (same); LG Chem, Ltd. v.
`
`Celgard, LLC, IPR2014-00692, Paper 76 at 44-45 (P.T.A.B. Oct. 5, 2015) (same).
`
`And as for Rule 703’s requirement that the facts or data are those which
`
`“experts in the particular field would reasonably rely on,” Arkema’s own expert
`
`described stability and miscibility testing—like those set forth in Exhibit 2103—as
`
`“routine, industry standard test[s].” Ex. 1002 ¶ 105 (miscibility); ¶ 109 (stability).
`
`The Board therefore should hold that Exhibits 2101-2103 are admissible.
`
`B. Arkema Cites No Authority For Excluding the File History of a
`Challenged Patent
`
`Arkema’s primary argument for the declarations-at-issue being hearsay is
`
`that, because the declarations were not prepared specifically for this proceeding,
`
`Arkema could not, as a matter of routine discovery, depose Mr. Winick and Dr.
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`Thomas. Putting aside that Arkema could have asked the Board for additional
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`discovery if it truly wanted to depose those witnesses,2 Arkema cites no case in
`
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`2 Arkema knows full well that deposing declarants from the file history would be
`
`beyond routine discovery, 37 C.F.R. § 42.51(b)(1), requiring additional
`
`discovery from the Board on motion. Notably, after Honeywell declined to
`
`voluntarily make them available for deposition, when neither Mr. Winick nor
`
`
`
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`7
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`
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`
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`which portions of the file history of the patent challenged in a proceeding were
`
`excluded from the same proceeding.
`
`Arkema cites only one case excluding a declaration previously filed with the
`
`PTO from a post-grant proceeding: U.S. Endodontics, LLC v. Gold Standard
`
`Instruments, LLC, PGR2015-00019, Paper 54 at 38, 42 (P.T.A.B. Dec. 28, 2016).
`
`In Endodontics, the Board excluded a declaration that (1) was in the file history of
`
`a patent related to the challenged patent but was not in the file history of the
`
`challenged patent; and (2) the Patent Owner’s experts had not cited in their
`
`declarations. Because Exhibits 2101-2103 here are part of the ’017 patent’s file
`
`history and relied on by Honeywell’s declarants, Endodontics does not apply here.
`
`Arkema cites no authority for excluding part of the intrinsic record of a challenged
`
`patent.
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`To the contrary, in other cases Arkema cites, the Board suggested that
`
`declarations in a patent’s file history—even though prepared outside of the
`
`proceeding in which they were later introduced—are admissible. Rather the
`
`absence of a deposition is simply something which goes to the weight of that
`
`
`Dr. Thomas prepared affidavit testimony for this proceeding, Arkema elected
`
`not to seek their deposition via the appropriate vehicle of a motion for
`
`additional discovery. 37 C.F.R. § 42.51(b)(2).
`
`
`
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`8
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`
`
`
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`declaration. See Praxair Distribution, Inc. v. INO Therapeutics LLC, IPR2015-
`
`00529, Paper 33 at 2 (P.T.A.B. Dec. 22, 2015); Mexichem Amanco Holdings S.A.
`
`de C.V. v. Honeywell Int’l, Inc., IPR2013-00576, Paper 36 at 2-3 (P.T.A.B. Sept. 5,
`
`2014).
`
`In Mexichem Amanco Holdings S.A. de C.V. v. Honeywell Int’l, Inc.,
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`IPR2013-00576, Paper 36 at 2-3 (P.T.A.B. Sept. 5, 2014), Honeywell requested
`
`additional discovery to depose Dr. Shibanuma—a third party witness—as
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`Mexichem had
`
`introduced Dr. Shibanuma’s declaration
`
`from
`
`the
`
`‘366
`
`reexamination.3 The Board refused to compel the deposition, noting that instead it
`
`would take the absence of a deposition into account in weighing the declaration. Id.
`
`at 3.
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`Similarly, in Praxair Distribution, Inc. v. INO Therapeutics LLC, IPR2015-
`
`00529, Paper 33 at 2 (P.T.A.B. Dec. 22, 2015), the Petitioner moved for additional
`
`discovery to depose three declarants who had submitted declarations during
`
`prosecution of the challenged patent and which were cited by the Patent Owner’s
`
`expert. The Board, apparently recognizing that the declarations would be
`
`admissible, stated that the panel would determine the proper weight to give them
`
`
`3 The same declaration which is now the subject of Honeywell’s motion to
`
`exclude and which Arkema’s experts did not rely on.
`
`
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`9
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`
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`“depending on the context in which Patent Owner relies on those declarations.” Id.
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`Here, Honeywell’s experts are justifiably relying on the declarations, one of which
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`contains data which Arkema admits is “routine.”
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`The Board’s case law thus suggests that a declaration filed during the
`
`prosecution of a patent is admissible even if the declarant was not cross-examined
`
`during the proceeding challenging that patent. Rather, the absence of a deposition
`
`is simply something the Board takes into account when weighing the declaration.
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`Arkema did not even make any meaningful attempt to secure such depositions,
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`e.g., through a request for additional discovery, see 37 C.F.R. § 42.51(b)(2), and
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`instead now asks that the Board ignore parts of the prosecution history.
`
`C. Exhibits 2101-2103 Are Trustworthy Under Fed. R. Evid. 807
`
`Exhibits 2101-2103 have “equivalent circumstantial guarantees of
`
`trustworthiness” such that they are admissible under Fed. R. Evid. 807.
`
`Honeywell’s expert Dr. Bivens relies on Exhibits 2101 and 2102 to support his
`
`statements regarding Honeywell’s customers and his conclusion that Honeywell
`
`was expected to sell $1 billion of HFO-1234yf from 2012-2017. Ex. 2126 ¶ 173.
`
`These statements are not groundbreaking. Indeed, in comments submitted to
`
`the EPA, “Arkema commented that they estimate the global demand for HFO–
`
`1234yf in 2021 will be around 45,000 metric tons and they believe Honeywell and
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`DuPont [a Honeywell licensee] will only be able to supply half that amount.” Ex.
`
`
`
`
`10
`
`
`
`
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`2154 at 27. And Exhibits 2109 and 2122—Chemours4 documents to which Arkema
`
`did not object—estimated 24 million vehicles using HFO-1234yf by the end of
`
`2016, and 50 million vehicles by the end of 2017. Ex. 2109 at 1; Ex. 2122 at 2.
`
`Given that most cars use one pound of refrigerant, Ex. 2140 at 1, Mr. Winick’s
`
`sales forecast was, if anything, low. And as for Honeywell’s customers, Exhibit
`
`2122 lists 31 different car manufacturers using HFO-1234yf. Ex. 2122 at 2. As
`
`Honeywell and its licensees are the only suppliers of HFO-1234yf, the above sales
`
`are all attributable to Honeywell.
`
`Moreover, as to Exhibit 2103, Arkema already had—and took—the
`
`opportunity to depose not only Dr. Thomas, but also Dr. Rajiv Singh, an inventor
`
`on the ‘017 patent, about the data presented in Table 3 of Exhibits 2103 and 1057
`
`(and reproduced in Exhibit 1180). Specifically, during prosecution of the ‘366
`
`patent, Honeywell submitted a declaration from Dr. Singh, also an inventor of the
`
`‘366 patent, in which he disclosed and explained the same data set forth in Table 3.
`
`Ex. 2165 at 4. During litigation in the Eastern District of Pennsylvania between
`
`Arkema and Honeywell, Arkema deposed both Dr. Thomas and Dr. Singh, cross-
`
`
`4 Chemours, a Honeywell licensee, was created when DuPont spun off its
`
`performance chemicals division.
`
`
`
`
`11
`
`
`
`
`
`examining Dr. Singh about that very data. Ex. 2166 at 331:2-332:13, 359:21-
`
`371:15.
`
`There is no question that Dr. Thomas’ declaration (Ex. 2103), submitted
`
`during prosecution of the ’017 patent, and Dr. Singh’s declaration, submitted
`
`during prosecution of the ‘366 patent, are substantively identical. To the extent
`
`Arkema’s concern about the admissibility of Dr. Thomas’s declaration comes from
`
`doubts about the veracity of Table 3’s data, Arkema previously deposed Dr. Singh
`
`regarding that data’s source. Arkema also deposed Dr. Thomas in the prior
`
`litigation. Given that the declarations are substantively identical and Arkema
`
`deposed both Drs. Singh and Thomas, Arkema already had an adequate
`
`opportunity for cross-examination concerning Table 3.
`
`Exhibits 2101-2103 therefore have sufficient circumstantial guarantees of
`
`trustworthiness to make them admissible under the residual exception of Fed. R.
`
`Evid. 807. Arkema deposed Dr. Thomas and Dr. Singh regarding the statements at
`
`issue, both Dr. Thomas’s and Mr. Winick’s declarations were made under oath,
`
`and both witnesses were aware of the gravity of the proceedings, having made their
`
`declarations with the understanding that any “willful false statements may
`
`jeopardize the validity of the claims of the patent.” Ex. 2101 ¶ 15; Ex. 2102 ¶ 11;
`
`Ex. 2103 ¶ 28. As Arkema recognizes, while the right of cross-examination may be
`
`most important in guarding against the dangers of hearsay, the Supreme Court has
`
`
`
`
`12
`
`
`
`
`
`advised that “the oath [and] the witness’ awareness of the gravity of the
`
`proceedings” also minimize those dangers. Paper 36 at 9 (citing Williamson v.
`
`U.S., 512 U.S. 594, 598 (1994)).
`
`The cases Arkema cites do not support its argument. In United States v.
`
`Fernandez, 892 F.2d 976, 984 (11th Cir. 1989), cited in Endodontics, the Eleventh
`
`Circuit reversed a conviction for conspiracy based on the grand jury testimony of a
`
`witness who died before trial. There, however, the witness “was an almost
`
`comically unreliable character,” and the court noted that other appellate courts had
`
`admitted grand jury testimony under the residual exception. Id. at 983. Here, there
`
`is no allegation that either Dr. Thomas or Mr. Winick is an “unreliable character.”
`
`In Stokes v. City of Omaha, 23 F.3d 1362, 1366-67 (8th Cir. 1994), the
`
`Eighth Circuit reversed a judgment of age discrimination against a police officer
`
`based on a two-paragraph declaration admitted under the residual exception. The
`
`declaration was submitted by a former deputy chief of police who averred that the
`
`chief of police had a “philosophy was to weed out the old employees….” Id. at
`
`1366. Before trial, the former deputy chief died, and his declaration was admitted
`
`under the residual exception. Id. The court held that it was error to admit the
`
`declaration where his death “although untimely, was not unexpected,” where the
`
`plaintiff could have deposed the witness, and where the chief of police—who was
`
`accused of discrimination—was available for trial but had not been called. Id.
`
`
`
`
`13
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`
`
`
`
`Neither Fernandez nor Stokes apply here. The Thomas and Winick
`
`declarations were made under oath, are part of the file history of the challenged
`
`’017 patent, and are the subject of expert testimony. Moreover, Dr. Thomas and
`
`Dr. Singh—who submitted testimony almost identical to that in Ex. 2103 in an
`
`earlier proceeding—were both previously deposed by Arkema. There are sufficient
`
`guarantees of trustworthiness such that Exhibits 2101-2103 should be admitted.
`
`D. Exhibit 1057 Cannot Be Partially Excluded
`
`Arkema lastly makes an unprecedented and bewildering proposal that the
`
`Board admit only certain portions and exclude other selected portions of Arkema’s
`
`own exhibit, Exhibit 1057. See Paper 36 at 6. Yet Arkema cites absolutely no
`
`support for the partial exclusion of a document it introduced. Nor could it. Indeed,
`
`Fed. R. Evid. 106 generally allows one party to put in the remainder of a document
`
`when an opposing party submitted only a portion of that document. The Board has
`
`previously admonished a party for—without citing any support—attempting to
`
`prevent the other party from relying on evidence which the first party submitted.
`
`See Square, Inc. v. REM Holdings 3, LLC, IPR2014-00312, Paper 58 at 37
`
`(P.T.A.B. July 7, 2015) (denying Patent Owner’s motion to exclude Petitioner’s
`
`use of an exhibit properly admitted under FRE 801(d)(2), because “Patent Owner
`
`does not direct us to any authority supporting such a rule that once evidence is
`
`admitted, that same evidence can be excluded from discussion for other
`
`
`
`
`14
`
`
`
`
`
`purposes.”); see also Corning Optical Communications RF, LLC v. PPC
`
`Broadband, Inc., IPR2013-00345, Paper 76 at 51 (P.T.A.B. Nov. 21, 2014) (“At
`
`the outset, we observe that the content that PPC seeks to exclude was introduced
`
`into this proceeding by PPC. Paper 41, 4. The fact that PPC introduced and relied
`
`on Mr. Burris’s deposition testimony means PPC may not bar similar use of that
`
`evidence by Corning.”). Arkema’s request should thus be denied as a half-hearted
`
`attempt to tactically admit incomplete evidence or exclude evidence which it
`
`regrets introducing in the first place.
`
`III. CONCLUSION
`
`For the foregoing reasons, Petitioner’s Motion to Exclude should be denied.
`
`Date: April 17, 2017
`
`Eugene Goryunov (Reg. No. 61,579)
`egoryunov@kirkland.com
`KIRKLAND & ELLIS LLP
`300 North LaSalle
`Chicago, Illinois 60654
`Telephone: (312) 862-2000
`Fax: (312) 862-2200
`
`Respectfully submitted,
`
`/s/ Eugene Goryunov
`
`Gregg F. LoCascio, P.C. (Reg. No. 55,396)
`Noah Frank (Reg. No. 67,279)
`glocascio@kirkland.com
`noah.frank@kirkland.com
`KIRKLAND & ELLIS LLP
`655 Fifteenth Street, NW
`Suite 1200
`Washington, DC 20005
`Telephone: (202) 879-5200
`Fax: (202) 879-5200
`
`Attorneys For Patent Owner
`
`
`
`
`
`
`
`
`
`
`15
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a copy of the foregoing Patent
`
`Owner’s Opposition to Petitioner’s Motion to Exclude Under 37 C.F.R. § 42.64(c)
`
`was served on the 17th day of April, 2017, via electronic mail directed to counsel
`
`of record for the Petitioners:
`
`Mark D. Sweet
`Mark J. Feldstein
`Erin M. Sommers
`Charles W. Mitchell
`
`
`mark.sweet@finnegan.com
`mark.feldstein@finnegan.com
`erin.sommers@finnegan.com
`charles.mitchell@finnegan.com
`Arkema_PTAB@finnegan.com
`
`
`
`
`
`
`
`
`/s/ Eugene Goryunov
`Eugene Goryunov
`
`
`
`
`
`16
`
`
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