IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Parrot S.A. and Parrot, Inc.
`Petitioners,
`v.
`Drone Technologies, Inc.
`Patent Owner
`
`___________________
`
`Case IPR2014-00732
`
`U.S. Patent No. 8,106,748
`
`___________________
`
`
`
`Before HOWARD B. BLANKENSHIP, MATTHEW R. CLEMENTS, and
`CHRISTOPHER M. KAISER, Administrative Patent Judges.
`
`
`
`PETITIONER’S OPPOSITION TO
`PATENT OWNER’S MOTION TO EXCLUDE
`DECLARATION OF DR. RAFFAELLO D’ANDREA [EXHIBIT 1011]
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Parrot S.A. and Parrot, Inc.
`Petitioners,
`v.
`Drone Technologies, Inc.
`Patent Owner
`
`___________________
`
`Case IPR2014-00732
`
`U.S. Patent No. 8,106,748
`
`___________________
`
`
`
`Before HOWARD B. BLANKENSHIP, MATTHEW R. CLEMENTS, and
`CHRISTOPHER M. KAISER, Administrative Patent Judges.
`
`
`
`PETITIONER’S OPPOSITION TO
`PATENT OWNER’S MOTION TO EXCLUDE
`DECLARATION OF DR. RAFFAELLO D’ANDREA [EXHIBIT 1011]
`
`
`
`Case IPR2014-00732
`Petitioner’s Opposition to Patent Owner’s Motion to Exclude
`EXHIBIT LIST
`Reference Name
`U.S. Patent No. 8,106,748 (“the ’748 Patent”)
`
`Exhibit #
`Ex. 1001
`
`Ex. 1002
`
`Ex. 1003
`
`Ex. 1004
`
`Ex. 1005
`
`Ex. 1006
`
`Ex. 1007
`
`Ex. 1008
`
`Ex. 1009
`
`Ex. 1010
`
`Ex. 1011
`
`U.S. Patent No. 5,043,646 (“Smith”)
`
`French Patent No. 9901683 to Potiron
`
`Certified Translation of French Patent No. 9901683
`(“Potiron”)
`
`U.S. Pat. Pub. No. 2006/10144994 A1 (“Spirov”)
`
`EXHIBIT INTENTIONALLY LEFT BLANK
`
`U.S. Pat. No. 7,219,861 (“Barr”)
`
`U.S. Pat. No. 6,751,529 (“Fouche”)
`
`U.S. Pat. No. 7,145,551 (“Bathiche”)
`
`U.S. Pat. Pub. No. 2004/0263479 (“Shkolnikov”)
`
`Expert Declaration of Prof. Raffaello D’Andrea with
`Attachments A-C
`
`Ex. 1011, Att. A U.S. Patent No. 613,809 to Tesla (“Tesla”)
`
`Ex. 1011, Att. B U.S. Patent No. 3,101,569 to Giardina (“Giardina”)
`
`Ex. 1011, Att. C U.S. Patent No. 8,072,417 (“Jouanet”)
`
`Ex. 1012
`
`Ex. 1013
`
`Ex. 1014
`
`Ex. 1015
`
`Claim Chart Demonstrating Invalidity of the ’748 Patent
`
`Declaration of Deborah A. Skolaski
`
`Declaration of James E. Hopenfeld
`
`Declaration of Prof. Raffaello D’Andrea
`
`i
`
`
`
`Case IPR2014-00732
`Petitioner’s Opposition to Patent Owner’s Motion to Exclude
`
`Ex. 1016
`
`Ex. 1017
`
`Ex. 1018
`
`Prof. D’Andrea Deposition Transcript (Jan. 8, 2015)
`
`Email from Prof. Raffaello D’Andrea to James Hopenfeld
`dated April 30, 2014
`
`Email from James Hopenfeld to Prof. Raffaello D’Andrea
`dated April 29, 2014
`
`ii
`
`
`
`Case IPR2014-00732
`Petitioner’s Opposition to Patent Owner’s Motion to Exclude
`I.
`INTRODUCTION
`Petitioners Parrot S.A. and Parrot,
`
`Inc.
`
`(collectively “Petitioner”)
`
`respectfully submit this Opposition to Patent Owner’s Motion to Exclude (Paper
`
`19). Because Exhibit 1011, the Declaration of Dr. Raffaello D’Andrea Regarding
`
`U.S. Patent No. 8,106,748 (“the Declaration”) is admissible, Patent Owner’s
`
`motion to exclude should be denied.
`
`II.
`
`PATENT OWNER’S MOTION AND REQUESTED RELIEF IS
`UNTIMELY
`Patent Owner’s request to exclude Exhibit 1011, the Declaration of Prof.
`
`Raffaello D’Andrea in Support of Petitioner’s Petition to Institute Inter Partes
`
`Review, is untimely. Patent Owner bases its motion on the fact that Prof.
`
`D’Andrea’s declaration mistakenly
`
`included
`
`the signature page from his
`
`declaration in related proceeding, Case No. IPR2014-00730 (the ’730 Proceeding),
`
`and that, as result, he never signed his declaration.
`
`Objections to evidence, such as supporting declarations, are governed by 37
`
`C.F.R. § 42.64:
`
`§42.64 Objection; motion to exclude; motion in limine.
`*
`*
`*
`(b) Other evidence. For evidence other than deposition evidence:
`(1) Objection. Any objection to evidence submitted during a
`preliminary proceeding must be served within ten business days
`of the institution of the trial. Once a trial has been instituted,
`
`1
`
`
`
`Case IPR2014-00732
`Petitioner’s Opposition to Patent Owner’s Motion to Exclude
`any objection must be served within five business days of
`service of evidence to which the objection is directed. The
`objection must identify the grounds for the objection with
`sufficient particularity to allow correction in the form of
`supplemental evidence.
`*
`*
` *
`(c) Motion to exclude. A motion to exclude evidence must be filed
`to preserve any objection. The motion must identify the
`objections in the record in order and must explain the
`objections. The motion may be filed without prior authorization
`from the Board.
`Patent Owner failed to make a timely objection under § 42.64(b)(1). There
`
`is no dispute that Prof. D’Andrea’s declaration is evidence that was submitted
`
`during a preliminary proceeding. Prof. D’Andrea’s declaration was signed on
`
`April 30, 2014, and submitted with the Petition on May 6, 2014. Nor is there any
`
`dispute that Patent Owner did not object to Prof. D’Andrea’s declaration within ten
`
`business days of the institution of trial. Trial was instituted on October 28, 2014.
`
`Patent Owner claims to have objected to Prof. D’Andrea’s declaration on January
`
`22, 2015, more than two months after the statutory deadline to object.
`
`Without citation to any authority, Patent Owner seeks to be excused from the
`
`requirements of § 42.64(b)(1). Patent Owner claims that it was not aware of the
`
`allegedly defective signature until January 9, 2015, when Prof. D’Andrea was
`
`deposed for purposes of this proceeding and the ’730 Proceeding. At his
`2
`
`
`
`Case IPR2014-00732
`Petitioner’s Opposition to Patent Owner’s Motion to Exclude
`deposition, Patent Owner showed Prof. D’Andrea the signature that was submitted
`
`with his declaration in this proceeding, and Prof. D’Andrea confirmed that the
`
`signature page from his declaration filed in the ’730 Proceeding had been
`
`mistakenly attached.
`
`Patent Owner clearly was aware of the issue of the mistaken signature block
`
`prior to the deposition, but did not object. Patent Owner does not offer any
`
`explanation as to why it could not have objected within ten days of service of Prof.
`
`D’Andrea’s declaration, as the mistaken signature page was readily apparent.
`
`Even if the Board were to assume, as Patent Owner implicitly asks the Board
`
`to assume, that Patent Owner did not have knowledge of the mistake relating to the
`
`attachment of the signature page until Prof. D’Andrea’s deposition on January 9,
`
`2015, and that lack of knowledge is an excuse to avoid the requirements of §
`
`42.64(b)(1), Patent Owner’s objection remains untimely. Patent Owner cannot
`
`reasonably dispute that its January 22, 2015 “Objection” was submitted more than
`
`five days after “service” (January 9, 2015) of the “evidence” that allegedly gave
`
`Patent Owner knowledge of the defect.
`
`Patent Owner claims to have been made aware of “additional bases” for the
`
`inadmissibility of Ex. 1011 on February 9, 2015, when Petitioner filed a motion to
`
`correct Ex. 1011 and supporting declarations. Patent Owner does not explain what
`
`“additional bases” were revealed on February 9, 2015; nor does Patent Owner offer
`
`3
`
`
`
`Case IPR2014-00732
`Petitioner’s Opposition to Patent Owner’s Motion to Exclude
`any explanation why it could not have timely objected to the declaration in
`
`November 2014, within ten business days of the institution decision as is required
`
`by § 42.64(b), without the unknown “additional bases” allegedly revealed in
`
`February 2015. Patent Owner did not serve supplemental objections. Patent
`
`Owner does not cite any authority or evidence that its Opposition to Petitioner’s
`
`motion constitutes a valid objection under § 42.64(b)(1).
`
`III. PROF. D’ANDREA’S DECLARATION IS ADMISSIBLE
`Patent Owner would have this Board believe that Petitioner’s counsel,
`
`together with Prof. D’Andrea, somehow conspired to submit a declaration that
`
`Patent Owner supposes was not Prof. D’Andrea’s, and that Petitioner’s counsel and
`
`Prof. D’Andrea subsequently lied to cover up the alleged conspiracy. All of this
`
`because of a simple clerical error: the signature page from the Prof. D’Andrea’s
`
`declaration in the ’730 Proceeding was mistakenly submitted with the declaration
`
`in this proceeding.
`
`Patent Owner’s fantastic speculations are, of course, as false as they are
`
`unproven. This motion is just Patent Owner’s attempt to distract the Board from
`
`the merits of the Petition.
`
`What actually happened is much more mundane. As Prof. D’Andrea and
`
`counsel have testified, his declaration was created as follows:
`
`4
`
`
`
`Case IPR2014-00732
`Petitioner’s Opposition to Patent Owner’s Motion to Exclude
`Counsel for Petitioner sent Prof. D’Andrea the patents and prior art,
`1)
`
`along with instructions relating to the applicable law (Ex. 1016, 12:7-
`
`24; 19:2; 20:4);
`
`2)
`
`Prof. D’Andrea independently reviewed the material and drew initial
`
`conclusions (Ex. 1016, 21:6-22:9);
`
`3)
`
`Prof. D’Andrea supervised the creation of his declarations and claim
`
`charts, beginning with a two-day in person meeting with counsel at
`
`Prof. D’Andrea’s office in Zurich (Ex. 1016, 22:5-24:19; 26:1-7;
`
`16:21-17:22; 67:12-21);
`
`4)
`
`Prof. D’Andrea supervised the finalization of his declarations,
`
`including the correction of typographical errors, reviewing and
`
`exchanging drafts with counsel “two, three, four, five times until I was
`
`happy with the declaration.” (Ex. 1016, 67:23-68: 15);
`
`5)
`
`On April 30, 2014, having been satisfied that they were substantively
`
`complete (Ex. 1016, 69:1-23), Prof. D’Andrea signed the declarations
`
`and sent them electronically to counsel, giving instructions to counsel
`
`to correct any remaining typographical errors (Ex. 1015);
`
`6)
`
`Counsel for Petitioner received copies of Prof. D’Andrea’s signature
`
`pages, made additional
`
`typographical corrections, collated
`
`the
`
`declarations, and, on May 6, 2014, filed them along with their
`
`5
`
`
`
`Case IPR2014-00732
`Petitioner’s Opposition to Patent Owner’s Motion to Exclude
`respective petitions at the United States Patent Office (Exs. 1013 and
`
`1014);
`
`7)
`
`At Prof. D’Andrea’s deposition on January 9, 2015, counsel for
`
`Petitioner learned that the signature page for Prof. D’Andrea’s
`
`declaration in the ’730 Proceeding mistakenly was substituted for the
`
`signature page for the declaration submitted in this proceeding (Ex.
`
`1016, 74:4-10;
`
`8)
`
`After conducting an investigation, Parrot determined that errors had
`
`been made in collating the declaration and supporting materials (in
`
`addition to the incorrect signature block, Prof. D’Andrea’s CV had
`
`been omitted) and, after receiving permission from the Board, filed on
`
`February 9, 2015, a Motion to Correct Ex. 1011 (Paper 14), including
`
`supporting declarations from counsel and counsel’s administrative
`
`support.
`
`Patent Owner’s conspiracy story is based on a series of quotes taken out of
`
`context, baseless speculations, and outright falsehoods.
`
`A.
`
`The April 30, 2014 email enclosing the signature pages is
`authentic
`Patent Owner first asserts that Prof. D’Andrea didn’t know whether he
`
`actually signed his declaration. A review of the complete transcript demonstrates,
`
`6
`
`
`
`Case IPR2014-00732
`Petitioner’s Opposition to Patent Owner’s Motion to Exclude
`however, that Prof. D’Andrea merely testified that he did not specifically
`
`remember actually signing the declaration. He repeatedly testified that he had
`
`signed the declaration personally. After being shown the signature page of his
`
`declaration in the ’730 Proceeding, Prof. D’Andrea confirmed that it was his
`
`signature, and then testified that “there must be” a corresponding signature for the
`
`declaration in this proceeding. Ex. 1016, 72:6-23. After Patent Owner’s counsel
`
`suggested that the possibility that Prof. D’Andrea did not sign the declaration for
`
`the ’732 Proceeding, Prof. D’Andrea reiterated his testimony that the signature
`
`must exist, and that it would be “very strange” if that were not the case. Ex. 1016
`
`72:24-73:15. After being shown that the signature block from the declaration for
`
`the ’730 Proceeding had been attached to his declaration for this proceeding, he
`
`testified that “It must have been a mistake.” Ex. 1016, 73:22:74:10.
`
`In Petitioner’s February 9, 2015 Motion to Correct Ex. 1011 Petitioner
`
`provided to Patent Owner a copy of the email proving that Prof. D’Andrea sent
`
`both signature pages, with instructions, on April 30, 2014, to counsel, just as Prof.
`
`D’Andrea testified. That should have been enough to settle the matter. However,
`
`Patent Owner now claims that the April 30, 2014, email was “doctored.” Patent
`
`Owner essentially accuses at least Petitioner’s counsel, and perhaps Prof.
`
`D’Andrea as well, of altering/falsifying evidence.
`
`7
`
`
`
`Case IPR2014-00732
`Petitioner’s Opposition to Patent Owner’s Motion to Exclude
`Patent Owner’s accusations are false. Patent Owner’s first allegation is that
`
`the “To” and “Cc” fields were removed from the April 30, 2014 email submitted
`
`with Petitioner’s February 9, 2015 Motion to Correct Ex. 1011. Although the
`
`reason for this is not entirely clear, the removal appears to be an artifact of the
`
`“print to pdf” feature of the version of Adobe Acrobat then available on counsel’s
`
`paralegal’s computer (Ms. Deborah Skolaski). Ms. Skolaski received the email as
`
`a “cc.” The “To” recipient was Petitioner’s counsel Mr. Hopenfeld; Petitioner’s
`
`counsel Ms. Terry also was cc’d. To remove any doubt, Petitioner has reprinted
`
`the preserved copy of the email using an updated version of Adobe Acrobat
`
`Professional, showing the “To” and “Cc” fields, and attached a true and correct
`
`copy to this response. Ex. 1017.
`
`Patent Owner’s next allegation is that the time stamp of the email enclosing
`
`the pdfs of the declarations for Prof. D’Andrea’s signature was 6:26 A.M., which
`
`is, by Patent Owner’s math, later than the 5:33 A.M. time stamp on the email Ms.
`
`Skolaski received by cc with Prof. D’Andrea’s signatures. The explanation is
`
`simple: The time stamps are local receipt times, and the emails were received in
`
`different time zones. The email from Prof. D’Andrea enclosing his signatures was
`
`received by Ms. Skolaski on April 30, 2014, at 5:33 A.M. Central time in Houston,
`
`Texas, which is 12:33 P.M. in Zurich. The time stamp on the enclosed email from
`
`Mr. Hopenfeld enclosing the declarations for signature is 6:26 A.M. Zurich time,
`
`8
`
`
`
`Case IPR2014-00732
`Petitioner’s Opposition to Patent Owner’s Motion to Exclude
`which is 11:26 P.M. (April 29) Central (Houston) time, when the email was sent.
`
`Attached is a true and correct copy of the enclosed email from Mr. Hopenfeld’s
`
`email files, showing that it was indeed sent April 29 at 11:26 P.M. Ex. 2018.
`
`Accordingly, Prof. D’Andrea returned his signed declarations approximately six
`
`hours after receiving them in the morning of April 30.
`
`Patent Owner speculates that Prof. D’Andrea does not have a record of the
`
`email. Even if this were true, it is irrelevant. Petitioner’s counsel took
`
`responsibility for archiving correspondence with Prof. D’Andrea. The above
`
`demonstrates that the April 30 email showing that Prof. D’Andrea did in fact sign
`
`his declarations on April 30 is in fact authentic, so there is no need to submit
`
`another copy.
`
`Prof. D’Andrea’s signatures are authentic
`B.
`Patent Owner points out that Prof. D’Andrea’s signatures in the April 30
`
`email do not have artifacts showing they were printed on A4 off-white paper, the
`
`paper usually used by Prof. D’Andrea. It is entirely unclear what Patent Owner
`
`means to demonstrate by this. It simply does not matter what paper Prof.
`
`D’Andrea used, whether or not he used paper conforming with his regular practice,
`
`and whether or not “artifacts” of that paper showed up on the pdf enclosed in the
`
`email from Prof. D’Andrea to counsel. What matters is that the signatures on the
`
`enclosed papers are in fact Prof. D’Andrea’s signatures, and the April 30 time
`
`9
`
`
`
`Case IPR2014-00732
`Petitioner’s Opposition to Patent Owner’s Motion to Exclude
`stamp shows those signatures were made on that date. Importantly, Patent Owner
`
`does not dispute that the signatures are Prof. D’Andrea’s or that he took
`
`responsibility for all content in the declarations.
`
`Prof. D’Andrea did not sign his declaration in Zurich at his home office,
`
`which likely accounts for the fact that the signature may not have been on A4
`
`paper. Ex. 1016, 70:19-71:3.
`
`C.
`
`Prof. D’Andrea’s curative declaration confirms that he signed
`and sent declaration signatures on April 30, 2014
`Patent Owner contends that Prof. D’Andrea’s use of “on or about” in his
`
`declaration submitted with Petitioner’s Motion to Correct Ex. 1011, Paper 14,
`
`somehow proves he did not send the email on April 30, 2014, enclosing his
`
`signature page. A review of Prof. D’Andrea’s declaration demonstrates otherwise.
`
`Not only does he confirm signature, he attaches a copy of the email of that date
`
`enclosing his signature pages, providing independent, corroborated proof of the
`
`April 30, 2014 date.
`
`D.
`
`The precise times at which Petitioner’s counsel and support staff
`learned of signature page error are irrelevant
`Patent Owner’s argument that Petitioner’s declarations are inconsistent as to
`
`when Petitioner learned that Prof. D’Andrea’s declaration had been collated with
`
`the incorrect signature page is based on incomplete cropped quotes and is
`
`misleading. Paper 19, 8. All these quotes show is that certain persons learned of
`
`10
`
`
`
`Case IPR2014-00732
`Petitioner’s Opposition to Patent Owner’s Motion to Exclude
`the error at slightly different times. Ms. Terry’s quote in Ex. 2014 refers not to the
`
`time that Petitioner learned about the error, but rather when Petitioner learned that
`
`the error was subject to Patent Owner’s objection and that correction may be
`
`necessary.
`
`There were no material changes to Prof. D’Andrea’s Declaration
`E.
`Patent Owner speculates—without any evidence whatsoever—that Prof.
`
`D’Andrea’s declaration somehow materially changed between April 30, 2014,
`
`when he signed it, and May 6, 2014, when it was submitted to the Patent Office.
`
`The record is unequivocal that the only changes made were typographical and
`
`expressly authorized by Prof. D’Andrea. Patent Owner had ample time to question
`
`Prof. D’Andrea about his technical opinions at his deposition. Patent Owner did
`
`not identify a single opinion that was not in fact Prof. D’Andrea’s. At his
`
`deposition, and as stated above, Prof. D’Andrea already had reviewed his
`
`declarations several times prior to signature, confirming his satisfaction with the
`
`facts and opinions expressed in them. Ex. 1016, 67:23-68:5; 69:16-20.
`
`F.
`
`The identity of the paralegal who made the collation error is not
`relevant
`The identity of the paralegal who actually made the collation error is not
`
`relevant to Patent Owner’s motion or to this proceeding.
`
`11
`
`
`
`Case IPR2014-00732
`Petitioner’s Opposition to Patent Owner’s Motion to Exclude
`G.
`Prof. D’Andrea wrote and understood what was in his declaration
`In a rehash of other arguments, Patent Owner speculates that Prof. D’Andrea
`
`didn’t understand what was in the declaration when he signed it. Patent Owner
`
`ignores Prof. D’Andrea’s deposition testimony, which demonstrates that at the
`
`time he wrote the April 30, 2014 email stating that he was leaving any further
`
`typographical corrections to counsel, he had already satisfied himself that the draft
`
`was complete. Ex. 1016, 67:23-68:5; 69:16-20. Prof. D’Andrea testified
`
`unequivocally that he was the creator of the declarations. Ex. 1016, 15:9-16:5;
`
`16:15-20.
`
`H. The location of the signature page after the cover sheet does not
`matter
`Patent Owner supposes alteration of
`
`the declaration, despite Prof.
`
`D’Andrea’s testimony to the contrary, based on the fact that the signature page
`
`appears after the cover page, which is “unusual.” Patent Owner is correct that the
`
`location of the signature page was deliberate. Because correction of typographical
`
`errors or document reformatting could have potentially changed paginations, the
`
`signature block was included after the cover page to eliminate the need for Prof.
`
`D’Andrea to re-sign his declaration. This, however, has nothing to do with the
`
`admissibility of the declaration, which is the only issue in a motion to exclude.
`
`12
`
`
`
`Case IPR2014-00732
`Petitioner’s Opposition to Patent Owner’s Motion to Exclude
`I.
`Petitioner produced what it was obligated to produce, and more
`Patent Owner complains that Petitioner did not produce Prof. D’Andrea’s
`
`draft declarations and did not produce an authentic version of Prof. D’Andrea’s
`
`April 30, 2014, email enclosing his signature pages. Petitioner had no obligation
`
`to produce draft declarations, much less email enclosing them, particularly in the
`
`absence of any valid request for such documents or authorization by the Board for
`
`such additional discovery under the applicable rules in this proceeding.
`
`IV. CONCLUSION
`For the above reasons, Petitioner requests that the Board deny Patent
`
`Owner’s Motion to Exclude and find all Petitioner exhibits admissible in this
`
`proceeding.
`
`Dated: June 10, 2015
`
`Respectfully submitted,
`
`
`
`/s/ James E. Hopenfeld
`James E. Hopenfeld (Reg No. 47,661)
`Hopefeld@oshaliang.com
`Tammy J. Terry (Reg No. 69,167)
`Terry@oshaliang.com
`OSHA LIANG LLP
`909 Fannin Street, Suite 3500
`Houston, Texas 77010
`Tel: 713.228.8600/Fax: 713.228.8778
`Counsel for Petitioner
`
`13
`
`
`
`Case IPR2014-00732
`Petitioner’s Opposition to Patent Owner’s Motion to Exclude
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies service pursuant to 37 C.F.R. § 42.6(e) on the
`
`Patent Owner by email and U.S. Mail a copy of this Opposition to Patent Owner’s
`
`Motion to Exclude Declaration of Dr. Raffaello D’Andrea [Exhibit 1011] as
`
`follows:
`
`Gene Tabachnick
`James Dilmore
`gtabachnick@beckthomas.com
`jdilmore@beckthomas.com
`docket@beckthomas.com
`BECK & THOMAS, P.C.
`1575 McFarland Road, Suite 100
`Pittsburgh, PA 15216-1808
`
`Respectfully submitted,
`
`/James E. Hopenfeld/
`James E. Hopenfeld
`
`
`
`
`
`Dated: June 10, 2015
`
`
`
`
`
`
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