UNITED STATES PATENT AND TRADEMARK OFFICE
`
`______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`______________
`
`JIAWEI TECHNOLOGY (HK) LTD., JIAWEI TECHNOLOGY (USA) LTD.,
`SHENZHEN JIAWEI PHOTOVOLTAIC LIGHTING CO., LTD., ATICO
`INTERNATIONAL (ASIA) LTD., ATICO INTERNATIONAL USA, INC.,
`CHIEN LUEN INDUSTRIES CO., LTD., INC. (SHIEN LUEN FLORIDA),
`CHIEN LUEN INDUSTRIES CO., LTD., INC. (SHIEN LUEN CHINA),
`COLEMAN CABLE, LLC, NATURE’S MARK, RITE AID CORP., SMART
`SOLAR, INC., AND TEST RITE PRODUCTS CORP.
`Petitioner,
`
`v.
`
`SIMON NICHOLAS RICHMOND
`Patent Owner.
`______________
`
`Case No. IPR2014-00938
`Patent 7,429,827
`
`PETITIONER'S OPPOSITION TO PATENT OWNER’S
`MOTION TO EXCLUDE EVIDENCE
`
`
`
`______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`______________
`
`JIAWEI TECHNOLOGY (HK) LTD., JIAWEI TECHNOLOGY (USA) LTD.,
`SHENZHEN JIAWEI PHOTOVOLTAIC LIGHTING CO., LTD., ATICO
`INTERNATIONAL (ASIA) LTD., ATICO INTERNATIONAL USA, INC.,
`CHIEN LUEN INDUSTRIES CO., LTD., INC. (SHIEN LUEN FLORIDA),
`CHIEN LUEN INDUSTRIES CO., LTD., INC. (SHIEN LUEN CHINA),
`COLEMAN CABLE, LLC, NATURE’S MARK, RITE AID CORP., SMART
`SOLAR, INC., AND TEST RITE PRODUCTS CORP.
`Petitioner,
`
`v.
`
`SIMON NICHOLAS RICHMOND
`Patent Owner.
`______________
`
`Case No. IPR2014-00938
`Patent 7,429,827
`
`PETITIONER'S OPPOSITION TO PATENT OWNER’S
`MOTION TO EXCLUDE EVIDENCE
`
`
`
`I.
`
`INTRODUCTION
`
`Patent Owner’s Motion to Exclude Evidence (“Motion”) should be denied.
`
`Patent owner argues (i) that certain exhibits should be struck because they are
`
`belated, (ii) that other exhibits violate the Federal Rules of Evidence, and (iii) that
`
`certain portions of the cross-examination of its expert (Dr. Ducharme) should be
`
`excluded because the questions allegedly were misleading, argumentative,
`
`ambiguous, and/or compound. Patent owner is incorrect.
`
`First, the allegedly belated exhibits are not belated, but were provided in
`
`direct reply to arguments that patent owner raised
`
`in its response, which is
`
`permitted. Second, none of petitioner’s exhibits violate the Federal Rules of
`
`Evidence (e.g., the use of dictionaries to provide meanings to claim terms is
`
`common); and is warranted in petitioner’s reply because patent owner attempted to
`
`reargue the construction of “varying colour” and “accessible” in its response.
`
`Third, contrary to patent owner’s position, petitioner’s questions were fair, and the
`
`questions were understood by Dr. Ducharme. That patent owner does not like the
`
`answers that its expert provided is not reason to exclude them. And, in any event,
`
`the Board can judge the probative value of the testimony.
`
`It should not be
`
`excluded.
`
`1
`
`
`
`II. ARGUMENT
`
`A. Petitioner’s Exhibits Are Timely And Provided In
`Direct Response to Patent Owner’s Response.
`
`It is well understood that “[a] reply may only respond to arguments raised in
`
`the corresponding opposition.” 37 C.F.R. § 42.23; Office Patent Trial Practice
`
`Guide, 77 Fed. Reg. at 48767. Stated differently, even if the reply relies on new
`
`evidence or expands on arguments, this cannot establish impropriety of such
`
`evidence or the inadmissibility of the evidence under the Federal Rules of
`
`Evidence. See Case CBM2013-00009, paper 68 at 43 (Feb. 11, 2014). Thus,
`
`“[t]he very nature of a reply is to respond to the opposition, which in this case is
`
`the Patent Owner Response.” Microsoft Corp. v. SurfCast, Inc., 2014 WL
`
`5337868, at *30 (Oct. 14, 2014); see 37 C.F.R. § 42.23(b). As such, where patent
`
`owner raised issues for the first time in its patent owner response, the petitioner
`
`may address those issues in its reply. See St. Jude Med., Cardiology Div., Inc.,v.
`
`Board of Regents of Univ. of Mich., 2014 WL 1783276, at *20 (May 1, 2014). (“A
`
`petitioner is not expected to anticipate, in its petition, every counterargument a
`
`patent owner might make in response.”).
`
`Here, patent owner argues that paragraphs 26-27, 35-38, 50, and 69 of the
`
`Declaration of Peter Shackle (Ex. 1047) (“Shackle II”) provided in reply to patent
`
`owner’s response are belated. Patent owner also argues that exhibits 1048-1057
`
`(LinkedIn and Atlas Profiles), exhibits 1058-1062 (dictionary definitions and
`
`2
`
`
`
`thesaurus), and exhibit 1063 (Ducharme expert report from earlier case against
`
`IDC) are untimely. This testimony and the accompanying exhibits should be
`
`permitted, however, because they directly respond to arguments that patent owner
`
`raised in its Response.
`
`1.
`Patent Owner’s Failure to Meaningfully Discuss
`the Arguments in its Response that Triggered the
`Allegedly Belated Testimony and Exhibits is a Basis for
`Denial.
`
`Patent owner’s motion should be denied at the outset because patent owner
`
`does not even discuss the arguments it made in its response that led to the allegedly
`
`improper evidence being included in the Reply. See CBM2013-00009, paper 68 at
`
`43–44) (“[Movant’s] motion does not, however, contain any meaningful discussion
`
`of the arguments [Movant] has made in its patent owner response, which
`
`reasonably might have triggered [Petitioner’s] reliance on the testimony [Movant]
`
`now seeks to exclude. Without such an analysis, [Movant] has not shown that the
`
`reply declarations . . . and documentary evidence . . ., exceed the proper scope of
`
`reply evidence.”) (citations omitted). Specifically, patent owner does not discuss
`
`that paragraphs 26-27 of Shackle II and exhibits 1048-1057 are in direct response
`
`to patent owner’s contention that petitioner assessed the level of skill in the art too
`
`high and the evidence provided by patent owner. See generally PO Resp., Paper
`
`No. 34 at 10-14; Duchm. Decl., Ex. 2021 at ¶¶ 51-58. Similarly, paragraphs 20,
`
`35-38 of Shackle II are in direct response to patent owner’s allegations that Dr.
`
`3
`
`
`
`Shackle is not qualified to testify. See PO Resp., Paper 34 at 14-15, Duchm. Decl.,
`
`Ex. 2021 at ¶¶ 32-34, 36. And exhibits 1058-1063 and ¶¶ 50 and 69 of Shackle II
`
`are in response to patent owner’s attempt to reargue the construction of “varying
`
`colour,” and to construe “accessible” for the first time, in its response. See PO
`
`Resp., Paper No. 34 at 20-21; Duchm. Decl., Ex. 2021 at ¶¶ 74-77. Patent owner’s
`
`failure to even identify these arguments that led to petitioner’s expert’s testimony
`
`and exhibits alone justifies denying patent owner’s motion.
`
`2.
`Petitioner’s Evidence in Reply to Patent Owner’s
`Challenge to the Level of Skill in the Art is Timely.
`
`Patent owner submitted evidence that the prior art allegedly indicated a level
`
`of skill lower than the level of skill in the art proposed by petitioner. This evidence
`
`took the form of citing to the level of education of the named inventors of certain
`
`patents. See PO Resp., Paper 34 at 12-14; see generally Duchm. Decl., Ex. 2021 at
`
`¶¶ 51-56 and specifically at ¶¶ 57-58. Dr. Ducharme further states he is “aware
`
`that only a handful of the inventors of the prior art patents in this case are electrical
`
`engineers.” Duchm. Decl., Ex. 2021 at ¶ 52.
`
`Dr. Shackle’s paragraphs 26-27 and exhibits 1048-1057 provide testimony
`
`and evidence that educational level of many of the named inventors of the prior art
`
`patents of record is at least a Bachelor’s degree (as petitioner contends) or in many
`
`cases greater. This testimony and evidence thus directly rebuts an argument raised
`
`by the patent owner for the first time in its response and should be permitted.
`
`4
`
`
`
`3.
`Petitioner should be Permitted to Rebut a
`Challenge to its Expert’s Qualifications Even Where
`Such a Challenge Lacks Merit.
`
`Petitioner’s expert (Shackle) is a Ph.D. Physicist with 20+ years of
`
`experience in lighting electronics. Nonetheless, patent owner alleged that Dr.
`
`Shackle is not qualified to testify because he allegedly never supervised engineers
`
`in the design of solar lights, did not have experience with photodiodes, and had not
`
`designed consumer products and, in particular, products to be manufactured in
`
`China. See PO Resp., Paper 34 at 11-12, Duchm. Decl., Ex. 2021 at ¶¶ 32-34, 36.
`
`In response to this challenge, Dr. Shackle expanded on testimony previously
`
`provided in his Declaration (see Shackle Decl., Ex. 1002 at ¶¶ 2-5, 32-33) and
`
`during his deposition (see Shackle Depo., Ex. 2022 at 7:21-11:17). While not in
`
`his original declaration and not specifically called out in his CV, the additional
`
`testimony in paragraphs 35-38 of his second declaration was provided to directly
`
`rebut patent owner’s challenge; namely, that Dr. Shackle had experience with solar
`
`cells, photovoltaic cells and solar powered products (¶¶ 35-36), had experience in
`
`the design of consumer products (¶ 37), and had experience in the design of
`
`consumer products and transferring products to China for manufacture (¶ 38).
`
`Petitioner does not agree that these experiences are necessary for Dr. Shackle to
`
`testify competently; however, due to patent owner’s challenge to his qualifications,
`
`Dr. Shackle provided additional sworn testimony addressing these issues.
`
`5
`
`
`
`4.
`
`Response to Claim Construction Arguments.
`
`In its response, patent owner reargues the construction of the term “varying
`
`colour,” and also construed the term “accessible” in the phrase “switch being
`
`accessible by the user” for the first time. See PO Resp., Paper 34 at 20-21; Duchm.
`
`Decl., Ex. 2021 at ¶¶ 74-77. Because “the Board's construction of a claim term in
`
`a Decision to Institute is not final, and is reviewable in light of both parties’
`
`subsequent briefings and oral argument” (see Microsoft Corp. v. Surfcast, Inc.,
`
`2014 WL 5337868, at *28 (Oct. 14, 2014)), petitioner’s reply addressed these
`
`issues. Moreover, where, as here, “the patent owner response makes an argument
`
`that reasonably could not have been anticipated by Petitioner,
`
`the Petitioner
`
`properly may, as a part of its reply, rely on new evidence or cite to different
`
`portions of the same prior art reference.” CBM2013-00009, paper 68, at 46 (Feb.
`
`11, 2014).
`
`Exhibits 1058-1060 are in direct response to patent owner’s continued
`
`argument regarding the claim construction of “varying colour.” The Board
`
`rejected both parties claim constructions for “varying color” in its decision on
`
`institution. The Board construed “varying color” as “a perceptible changing of
`
`color over time.” (Dec., Paper 20 at 8). Petitioner agrees with that construction for
`
`this proceeding. Patent owner, however disagrees, and through Dr. Ducharme
`
`continues to attempt to read limitations from the specification into the claims to
`
`6
`
`
`
`present an ever evolving construction for “varying color.” See e.g., Duchm. Depo.
`
`Ex. 1046 at 99:17-24) (“varying color” is simply “transitioning from one color to
`
`another.”); see generally id. at 99:25-103:12 (“varying color” is “changing color”
`
`by “ramping up and ramping down”); id. at 105:7-24. But, when asked where to
`
`determined the meaning of “varying” in the term “varying color.” Dr. Ducharme
`
`indicated to look to a general dictionary. Duchm. Depo, Ex. 1046 at 105:15-24.
`
`Exhibits 1058-60 are definitions of “varying” from dictionaries and examples of
`
`synonyms for “varying” from Roget’s Thesaurus, each of which supports
`
`petitioner’s and the Board’s definition. See also Shackle II, Ex. 2047 at ¶ 43-45
`
`Exhibits 1061 and 1062 (and paragraph 50 of Ex. 1047) address patent
`
`owner’s continued efforts to construe “accessible.”
`
`The term is construed to mean, “the switch is accessible to the user
`without substantial effort, tools, or destruction.” Therefore, a switch
`need not be exposed and the user can disassemble the device, e.g.,
`remove a few screws, unscrew a lens, etc., to gain access to the
`switch. Therefore, a switch need not be exposed and the user can
`disassemble the device, e.g., remove a few screws, unscrew a lens,
`etc., to gain access to the switch.
`
`(emphasis added). Thus, paragraphs 50 of exhibit 1047 and exhibits 1061-
`
`62 are timely and directly respond to patent owner’s arguments. See also Shackle
`
`II, Ex. 1047 at ¶ 56.).
`
`7
`
`
`
`Finally, Paragraph 69 and Exhibit 1063 address patent owner’s and Dr.
`
`Ducharme’s erroneous reading of Chliwnyj to limit its plurality of LEDs to only
`
`those disclosed in the specification. Dr. Ducharme and patent owner agreed with
`
`Dr. Shackle, stating, “[t]he overlap of red, blue and/or green light, in certain
`
`proportions, can create any color perceivable to the human eye, including white
`
`light.” PO Resp., Paper No. 34 at 32; Duchm. Decl., Ex. 2021 at ¶ 98; Shackle I,
`
`Ex. 1002 at ¶ 43.
`
`In paragraph 69, Dr. Shackle cited Dr. Ducharme’s previous
`
`testimony and experiment regarding red, blue, and green Super Bright LEDs. Dr.
`
`Ducharme testified that Chliwnyj did not rule out any colors. Duchm. Depo., Ex.
`
`1046 at 138:13-24 (“Did he [Chliwnyj] specifically say you should not use a
`
`particular color? I don’t recall seeing that.” Chliwnyj also was clear that the
`
`“invention is not in any way limited to a particular choice of … LEDs” (Ex. 1005,
`
`at 15:1-3), and that the invention could be utilized with many different kinds of
`
`LEDs or other lamps. Id. at 15:3-51. See also Shackle II, Ex. 1047 at ¶¶ 57.
`
`1 Finally, even if the exhibits are deemed belated (which they should not be), the
`
`Board may consider them. See Alcohol Monitoring, Paper No. 40 at 12, Fn 1
`
`(“Although this argument is belated, see Office Patent Trial Practice Guide, 77
`
`Fed. Reg. at 48,768, we exercise our discretion and consider it.”). Given the
`
`8
`
`
`
`B. The Exhibits Do Not Violate The Federal Rules of
`Evidence.
`
`Patent owner objects to LinkedIn profiles as hearsay (FRE 801, 802) and to
`
`Dr. Shackle’s testimony regarding the named inventor’s of some of the prior art on
`
`the basis of lack of personal knowledge (FRE 6022). Patent owner also objects to
`
`the certain dictionary definitions on relevance (FRE 401) and prejudice (FRE 403)
`
`grounds. None of these objections have merit.
`
`First, the LinkedIn and Atlas profiles, although often hearsay, have been
`
`admitted by courts in similar contexts.
`
`See Music Grp. Macao Commercial
`
`Offshore Ltd. v. Foote, No. 14-CV-03078-JSC, 2015 WL 3882448, at *8 (N.D.
`
`Cal. June 23, 2015) (“The Court will consider the LinkedIn page only insofar as it
`
`is Defendant's description of himself as Chief Technology Officer, but not for the
`
`truth that Defendant was, in fact, Chief Technology Officer.”) Cf. Fed. R. Evid.
`
`801(c)(2) and 802. Also, because the PTAB proceeding must be completed within
`
`one year of institution, and the parties have limited discovery and time to obtain
`
`affidavits from third parties, some evidence that may be inadmissible is given
`
`importance of these issues, petitioner respectfully requests that the Board consider
`
`these exhibits.
`
`2 “This rule does not apply to a witness’s expert testimony under Rule 703.” Fed.
`
`R. Evid. 602.
`
`9
`
`
`
`weight. In this regard, the PTAB trial process is similar to a preliminary injunction
`
`proceeding that requires urgency by the Court and parties. See Loan Payment
`
`Admin. LLC v. Hubanks, No. 14-CV-04420-LHK, 2015 WL 1245895, at *6 (N.D.
`
`Cal. Mar. 17, 2015) (“In ruling on a motion for preliminary injunction, a court may
`
`consider evidence that would normally be inadmissible.”); see also Flynt Distrib.
`
`Co. v. Harvey, 734 F.2d 1389, 1394 (9th Cir.1984) (in deciding motion for
`
`preliminary injunction, “[t]he trial court may give even inadmissible evidence
`
`some weight” because “[t]he urgency of obtaining a preliminary injunction ...
`
`makes it difficult to obtain affidavits from persons who would be competent to
`
`testify at trial.”). Also, experts may rely on hearsay. See Fed. R. Evid. 703 (“An
`
`expert may base an opinion on facts or data in the case that the expert has been
`
`made aware of or personally observed.”); see Advanced Tech. Incubator, Inc. v.
`
`Sharp Corp., No. 2:07-CV-468, 2009 WL 4669854, at *10 (E.D. Tex. Sept. 15,
`
`2009) (“[A]n expert may rely upon otherwise inadmissible hearsay if it is ‘of a
`
`type reasonably relied upon by experts in the particular field in forming opinions or
`
`inferences upon the subject.’”) Here, it is reasonable for Dr. Shackle to rely upon
`
`evidence suggesting the education level of inventors in the field. See Shackle
`
`Decl., Ex. 1047 at ¶¶ 26-27. Given the timing of the PTAB proceeding, Linkedin
`
`profiles provide quick, cost effective access to this information and provide the
`
`reliable descriptions of the education of the profilees. Finally, the Board also may
`
`10
`
`
`
`consider any exhibit or testimony exercising its discretion. Alcohol Monitoring
`
`Systems, Inc. v. Soberlink, Inc., IPR2013-00577, Paper No. 40 at 12, Fn 1.
`
`Second,
`
`the dictionary definitions and thesaurus are admissible.
`
`The
`
`definitions are relevant because, as stated above, patent owner continues to
`
`advance arguments regarding the meaning of “varying colour.”
`
`Indeed, Dr.
`
`Ducharme demonstrated the relevance of this evidence when he stated that the best
`
`place to determined the meaning of “varying” was to look in a general dictionary.
`
`Duchm. Depo., Ex. 1046 at 105:15-24. It is well established that dictionaries may
`
`be relevant in construing claims. See Phillips v. AWH Corp., 415 F.3d 1303, 1318
`
`(Fed. Cir. 2005) (“Because dictionaries, and especially technical dictionaries,
`
`endeavor to collect the accepted meanings of terms used in various fields of
`
`science and technology, those resources have been properly recognized as among
`
`the many tools that can assist the court in determining the meaning of particular
`
`terminology to those of skill in the art of the invention.”). Therefore, because
`
`patent owner continues to press for a different definition of “varying colour,” these
`
`exhibits are relevant.3
`
`3 Patent owner does not seek to exclude exhibits 1061-1062 (also dictionary
`
`definitions and thesaurus) on these grounds.
`
`11
`
`
`
`Nor is their probative value outweighed by a danger of unfair prejudice
`
`under Fed. R. Evid. 401 and 403. Both Dr. Ducharme and Phillips establish that
`
`the probative value of this evidence is high. That this evidence goes against patent
`
`owner’s position is not “unfair” prejudice, but
`
`rather demonstrates
`
`the
`
`incorrectness of patent owner’s proposed construction. As such, there are no 401
`
`or 403 issues with this evidence, and even if there were, the Board can accord the
`
`evidence the appropriate weight.
`
`C. Dr. Ducharme’s Testimony Regarding Chliwnyj’s User
`Interface should not be Excluded.
`
`Patent owner objects to this line of questioning due to a purported lack of
`
`foundation and because the questions were purportedly ambiguous, argumentative,
`
`and misleading. Patent owner is incorrect.
`
`As with the previous objection, patent owner fails to cite all of the relevant
`
`testimony to provide an incomplete picture of the questioning. Specifically,
`
`counsel laid the foundation for the line of questioning one question before patent
`
`owner begins its quotation:
`
`Q. (By Mr. Nelson) Okay. If you turn to the top of Column 4 [of the
`Chliwnyj reference], it says, "It is the further object of the present
`invention to provide a flame pattern stimulation device for relaxation
`which flame pattern a user may control by using a user -- a simple
`user interface." Do you see that?
`A. Yes.
`
`12
`
`
`
`Id. at 133:6-13. The foundation for the questions that followed,
`
`therefore,
`
`stemmed directly from the exhibit 1005, Chliwnyj, related to the relaxation
`
`embodiment that disclosed a user interface. See Shackle II, Ex. 1047 at ¶¶ 57-58
`
`and 60-61. As an expert witness, Dr. Ducharme was asked his opinion (not
`
`speculation) regarding the types of “simple user interfaces” in the context of
`
`Chliwnyj:
`
`Q. What kind of simple user interfaces are you aware of that could be
`used to control this device or the Chliwnyj device, for example?
`MR. BENAVIDES: Objection; form.
`THE WITNESS: What kind of interfaces?
`Id. at 133:14-19. There was nothing ambiguous, argumentative, or misleading
`
`about counsel’s questioning.
`
`Dr. Ducharme’s admission that “a switch is a switch” is highly probative.
`
`This testimony corroborates petitioner’s argument that switches are not novel; and
`
`that the placement of a switch is an obvious design choice: See Shackle II, Ex.
`
`1047 at ¶¶ 60-64. “A switch is a switch.” Its function is the same regardless of
`
`placement or type of switch. This testimony should not be excluded.
`
`13
`
`
`
`III.
`
`CONCLUSION
`
`Petitioner’s exhibit 1047 at ¶¶ 26-27, 35-38, 50 and 69, exhibits 1048-63,
`
`and Dr. Ducharme’s objected to testimony should not be excluded from the
`
`Board’s consideration.4
`
`Respectfully submitted,
`
`Dated: August 26, 2015
`
`233 South Wacker Drive
`Suite 7800
`Chicago, IL 60606-6306
`
`DENTONS US LLP
`
`/ Mark C. Nelson
`
`Mark C. Nelson
`Reg. No. 43,830
`Lissi Mojica
`Reg. No. 63,421
`Kevin Greenleaf
`Reg. No. 64,062
`Daniel Valenzuela
`Reg. No. 69,027
`
`4 In the Conclusion section of its motion, patent owner asks that paragraph 71 of
`
`Dr. Shackle’s second declaration be excluded. However, patent owner does not
`
`address paragraph 71 in the body of its Motion and thus petitioner is uncertain of
`
`the basis for the purported exclusion, or whether patent owner simply made a
`
`mistake.
`
`In any event, paragraph 71 is directly responsive to arguments patent
`
`owner made in its response and thus should not be excluded.
`
`14
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that a copy of the PETITIONER’S OPPOSITION
`
`TO PATENT OWNER’S MOTION TO EXCLUDE EVIDENCE for Inter Partes
`
`Review of U.S. Patent No. 7,429,827 was served on the Counsel for the Patent
`
`owner via email to these email addresses:
`
`tfshiells@shiellslaw.com
`admin@shiellslaw.com
`marcusb@tlpmb.com
`
`Respectfully submitted,
`
`Dated: __August 26, 2015_____
`
`___/Nona Durham/_________
`
`Nona Durham
`
`15
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