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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`SEVEN NETWORKS, LLC,
`Patent Owner.
`____________
`
`Case IPR2020-00425
`Patent 9,438,550
`____________
`
`
`
`
`
`PATENT OWNER’S SURREPLY
`
`
`
`
`
`
`
`TABLE OF CONTENTS
`
`Case IPR2020-00425
`Patent 9,438,550
`
`Page
`
`I.
`
`FINTIV’S FACTORS WEIGH STRONGLY AGAINST
`INSTITUTION. ............................................................................................ 2
`
`A. Fintiv Factor #1: Petitioner fails to demonstrate that “a stay exists
`or is likely to be granted if a proceeding is instituted.” ........................ 2
`
`B. Fintiv Factor #2: There is not even a remote “proximity of the
`court’s trial date to the Board’s projected statutory deadline.”............. 4
`
`C. Fintiv Factor #3: There has been immense “investment in the
`parallel proceeding by the court and parties.” ....................................... 5
`
`D. Fintiv Factor #4: There is substantial “overlap between issues
`raised in the petition and in the parallel proceeding.” ........................... 7
`
`E. Fintiv Factor #5: It is undisputed that “the petitioner and the
`defendant in the parallel proceeding are the same party.” .................... 9
`
`F.
`
`Fintiv Factor #6: “Other circumstances that impact the Board’s
`exercise of discretion, including the merits” favor non-institution. .... 10
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`- i -
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`TABLE OF AUTHORITIES
`
`Case IPR2020-00425
`Patent 9,438,550
`
`Page(s)
`
`COURT DECISIONS
`
`Intellectual Ventures I LLC v. T Mobile USA, Inc.,
`2:17-CV-00577-JRG, Dkt. 255 (E.D. Tex. Dec. 13, 2018) ..............................2, 3
`
`NFC Tech. LLC v. HTC Am., Inc.,
`13-CV-1058 (E.D. Tex. Mar. 11, 2015) ............................................................... 3
`
`St. Lawrence Commc’ns LLC v. ZTE Corp.,
`2017 U.S. Dist. LEXIS 84290 (E.D. Tex. Jan. 17, 2017) .................................... 3
`
`Uniloc USA, Inc. v. Samsung Elecs. Am., Inc.,
`16-CV-642-JRG, Dkt. 268 (E.D. Tex. Jun. 13, 2017) .......................................... 3
`
`
`
`AGENCY DECISIONS
`
`Apple Inc. v. Fintiv, Inc.,
`IPR2020-00019, Paper 11 (PTAB Mar. 20, 2020)
`(precedential) ..................................................................................... 1, 2, 4, 5, 10
`
`Apple, Inc. v. Fintiv, Inc.,
`IPR2020-00019, Paper 15 (PTAB May 13, 2020) ...........................................1, 5
`
`Apple, Inc. v. SEVEN Networks, LLC,
`IPR2020-00156, Paper 10 (PTAB Jun. 15, 2020) ............................................5, 6
`
`Apple, Inc. v. SEVEN Networks, LLC,
`IPR2020-00157, Paper 10 (PTAB Jun. 15, 2020) ............................................5, 6
`
`Ethicon, Inc. v. Bd. of Regents,
`IPR2019-00406, Paper 27 (PTAB Jun. 10, 2020) ................................................ 7
`
`- ii -
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`
`
`Intel Corp. v. VLSI Tech. LLC,
`IPR2020-00106, Paper 17 (PTAB May 5, 2020) .............................................1, 5
`
`Case IPR2020-00425
`Patent 9,438,550
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`Samsung Elec. v. Uniloc 2017 LLC,
`IPR2020-00117, Paper 11 (PTAB May 28, 2020) ............................................... 1
`
`Sand Revolution II, LLC v. Continental Intermodal Grp.,
`IPR 2019-01393, Paper 24 (PTAB Jun. 16, 2020). .............................................. 8
`
`
`
`STATUTES
`
`35 U.S.C. § 112(a) ..................................................................................................... 7
`
`35 U.S.C. § 325(d) ................................................................................................... 10
`
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`- iii -
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`2001
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`2002
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`2003
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`2004
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`2005
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`2006
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`Case IPR2020-00425
`Patent 9,438,550
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`EXHIBIT LIST
`
`Order, Mar. 27, 2020, SEVEN Networks, LLC v. Apple, Inc., No.
`2:19-cv-115-JRG (E.D. Tex.) [Amended Scheduling Order]
`
`Perkins Coie, Inter Partes Review Proceedings: A Fifth Anniversary
`Report (2017), https://issuu.com/perkinscoie/docs/2017_ipr_
`anniversary_report_5_final [2017 Report]
`
`Michelle Umberger & Lissa Koop, District Court Stays: A Review of
`the Past 12 Months, ManagingIP.com (Nov. 21, 2016), https://www.
`perkinscoie.com/images/content/1/6/v2/166020/Managing-IP-PC-
`Feature.pdf [District Court Stays]
`
`Intellectual Ventures I LLC v. T-Mobile USA, Inc., 2:17-CV-00577-
`JRG, Dkt. 255 (E.D. Tex. Dec. 13, 2018) [T-Mobile]
`
`Apple Inc.’s P.R. 3-3 and 3-4 First Supplemental Invalidity
`Contentions, Nov. 25, 2019, SEVEN Networks, LLC v. Apple, Inc.,
`No. 2:19-cv-115-JRG (E.D. Tex.) [Amended Invalidity Contentions]
`
`Order Focusing Patent Claims and Prior Art, July 31, 2019, SEVEN
`Networks, LLC v. Apple, Inc., No. 2:19-cv-115-JRG (E.D. Tex.)
`[Order Focusing Patent Claims]
`
`2007
`
`File History of Application No. 10/339,368 [Great-Grandparent FH]
`
`2008-2019 Reserved
`
`2020
`
`Innovation and Awards, SEVEN Networks, https://www.seven.com/
`about_us.innovation_awards.php (last visited Jun. 17, 2020)
`
`2021
`
`Madeline Holcombe, Fauci says second wave is ‘not inevitable’ as
`coronavirus cases climb in some states, CNN HEALTH (Jun. 13, 2020,
`10:15) https://www.cnn.com/2020/06/13/health/us-coronavirus-
`saturday/index.html [6/13 Article]
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`- iv -
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`
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`The Reply confirms that each Fintiv factor favors denial: 1) Petitioner does
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`Case IPR2020-00425
`Patent 9,438,550
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`not say it will move to stay and any such motion would be filed a week before
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`trial; 2) trial is 10+ months before the FWD deadline; 3) the Markman order issued
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`long ago and discovery will have concluded and pretrial disclosures made by the
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`DI deadline; 4) there is no difference between its invalidity theories and offers only
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`a fake “stipulation” that would remove no grounds from the District Court Action
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`and, indeed, seeks to increase the overlap; 5) Petitioner is the defendant in the
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`District Court Action; and 6) the Office has already considered Petitioner’s
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`arguments, which further supports denial.
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`Petitioner cites no case instituted under such facts and says little about the
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`actual Fintiv factors. The Reply’s first third is wasted on the supposedly “unique
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`facts of this case,” alleging Patent Owner is a “serial litigant” when it has sued just
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`four parties ever, is currently litigating just one case (including just one previously
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`asserted patent) and ignoring Seven’s $300M in product revenue, the 100M+
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`devices that installed its software, and the many awards it has received (Ex. 2020).
`
`Petitioner disparages the patents, but invalidity requires proof, not conclusory
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`assertions. Such policy arguments have been repeatedly rejected. Apple, Inc. v.
`
`Fintiv, Inc., IPR2020-00019, Paper 15, 10-12 (PTAB May 13, 2020); Intel Corp. v.
`
`VLSI Tech. LLC, IPR2020-00106, Paper 17, 14-15 (PTAB May 5, 2020); Samsung
`
`Elec. v. Uniloc 2017 LLC, IPR2020-00117, Paper 11, 10 (PTAB May 28, 2020).
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`- 1 -
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` Even when Petitioner purports to discuss Fintiv, it fails to do so, instead
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`Case IPR2020-00425
`Patent 9,438,550
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`rewriting and contorting nearly every factor. But Fintiv is binding precedent, and
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`Petitioner’s dramatic revisions are an invitation to legal error. Parties only need to
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`rewrite the law when the law is not in their favor and Petitioner’s gyrations are
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`tacit admissions that the Fintiv factors favor denial.
`
`I. FINTIV’S FACTORS WEIGH STRONGLY AGAINST INSTITUTION.
`
`A. Fintiv Factor #1: Petitioner fails to demonstrate that “a stay
`exists or is likely to be granted if a proceeding is instituted.”
`
`This factor unquestionably favors denial, for Petitioner has not said it would
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`move for a stay if one or more IPRs were instituted. Indeed, in the POPR, Patent
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`Owner wrote: “In the District Court Action, Petitioner has not moved for a stay or
`
`indicated that it would.” POPR, 10. If Petitioner had any intention of moving for
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`a stay under any circumstance, the Reply would have said so. Petitioner’s
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`continued silence confirms a stay will be neither sought nor entered.
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`Petitioner does not say it will move for a stay because any such motion
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`would be dead-on-arrival. Petitioner does not dispute that a stay would be denied
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`even if every petition-in-question were instituted. The POPR cites three decisions
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`denying stays. Id., 11. Petitioner neither mentions nor distinguishes any of them.
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`For example, in T-Mobile, though every claim-at-issue was instituted three months
`
`before trial, the stay motion was denied as what mattered was the “last and most
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`- 2 -
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`recent IPR [filed]” and “[h]aving elected to engage in parallel proceedings before
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`Case IPR2020-00425
`Patent 9,438,550
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`the PTAB and engaged in conduct that elongated the institution proceedings,
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`Defendants must now accept the consequences.” Ex. 2004 [T-Mobile] 5.
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`Here, it is undisputed the institution decision will be due just less than two
`
`months before the scheduled trial date. POPR, 5. Even that would be too late. But
`
`Petitioner elected to space its IPR petitions over many months, and institution in
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`the last filed petition is not due until October 26, 2020, just one week before trial.
`
`POPR, 12. Even assuming a motion to stay were filed immediately, the District
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`Court will not enter a stay filed a week before trial. See, e.g., St. Lawrence
`
`Commc’ns LLC v. ZTE Corp., 2017 U.S. Dist. LEXIS 84290 at *9-10 (E.D. Tex.
`
`Jan. 17, 2017) (Gilstrap) (denying stay motion filed four months before trial).
`
`Petitioner ignores these apposite cases in favor of two inapposite ones.
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`Reply, 4. In NFC Tech. LLC v. HTC Am., Inc., 13-CV-1058 (E.D. Tex. Mar. 11,
`
`2015) (Bryson), unlike this case, every patent-at-issue had an instituted IPR, fact
`
`discovery remained open, and the Court found it likely “the bulk of the expenses
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`that the parties would incur … are still in the future.” Id., 1-2, 6; 9 (“it is important
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`to the Court’s decision that … the PTAB … has instituted [IPR] proceedings on
`
`most of the claims at issue ...”). Uniloc USA, Inc. v. Samsung Elecs. Am., Inc., 16-
`
`CV-642-JRG, Dkt. 268 (E.D. Tex. Jun. 13, 2017) (Gilstrap) is similarly far afield,
`
`for IPRs were instituted as to all claims in three of four patents-at-issue, claim
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`- 3 -
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`construction had not occurred and discovery was open. Id., 2. Here, by contrast,
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`Case IPR2020-00425
`Patent 9,438,550
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`institution decisions have issued as to just 2 of 10 patents, claim construction has
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`concluded, and discovery will end prior to the DI deadline. POPR, 5; Ex. 2001, 3.
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`Petitioner concludes with a non sequitur. It speculates that if the IPRs are
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`instituted, that “has the potential to simplify other proceedings.” Reply, 4. This is
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`irrelevant to whether a stay will be granted here, and Petitioner does not identify
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`what “other proceedings” could be “simplif[ied],” as Patent Owner is only engaged
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`in patent litigation with Petitioner. Thus, in contrast to the IPR2020-00156/157
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`(“156/157”) cases between the parties, the first factor strongly favors denial.
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`B.
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`Fintiv Factor #2: There is not even a remote “proximity of the
`court’s trial date to the Board’s projected statutory deadline.”
`
`This factor also unquestionably favors denial, even more strongly than in the
`
`156/157 cases. “If the court’s trial date is earlier than the projected statutory
`
`deadline, the Board generally has weighed this fact in favor of exercising authority
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`to deny institution under NHK.” Apple Inc. v. Fintiv, Inc., IPR2020-00019, Paper
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`11, 9 (PTAB Mar. 20, 2020). The trial is scheduled to begin on November 2,
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`2020, over ten months before the FWD deadline of September 8, 2021, and that is
`
`after the parties already pushed back the trial date due to COVID-19. POPR, 3.
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`Petitioner does not respond to the POPR’s argument or dispute its facts.
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`Instead, it speculates that trial could move again as the court is busy—as if that
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`- 4 -
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`
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`were unusual—or due to a second COVID wave. Reply, 5. Contrary to the Reply,
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`Case IPR2020-00425
`Patent 9,438,550
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`Dr. Fauci has clarified: “It is not inevitable that you will have a so-called ‘second
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`wave’ in the fall ....” Ex. 2021 [6/13 Article] 1. The Board has consistently
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`rejected such arguments, even with just a two-month gap. Fintiv, IPR2020-00019,
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`Paper 15, 13 (denying institution with two month gap despite COVID uncertainty);
`
`VLSI Tech., IPR2020-00106, Paper 17, 7-8 (similar); POPR, 11-14, 22-24; 156/157
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`Cases, Paper 10, 8-9 (7½ month gap favored denial). Here, with the trial date
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`already pushed back, there is still an over 10-month gap. No one has suggested
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`pushing it back further, let alone by ¾ of a year. This factor strongly favors denial.
`
`C. Fintiv Factor #3: There has been immense “investment in the
`parallel proceeding by the court and parties.”
`
`In contrast to the 156/157 cases, this factor strongly favors denial. The
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`institution decision is due September 4, 2020, just 2 months before trial. The 101-
`
`page Markman order issued on March 31, the parties have made final elections of
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`claims and art, discovery will close, and final and rebuttal pretrial disclosures will
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`be made before the DI deadline. POPR, 5. The parties and district court have thus
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`invested incredible amounts of time and effort. Fintiv, 9-10 (“district court claim
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`construction orders may indicate that the court and parties have invested sufficient
`
`time in the parallel proceeding to favor denial.”); VLSI, IPR2020-00106, Paper 17,
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`8-9 (factor favored denial where Markman was three months earlier and fact
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`- 5 -
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`discovery closed two weeks after DI).
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`Case IPR2020-00425
`Patent 9,438,550
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`Petitioner does not dispute that this factor favors denial. Instead, it contends
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`it is simply “outweigh[ed]” by “Seven’s conduct” which allegedly dictated the
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`timing of Apple’s petitions. Reply, 5-8. This prolonged diatribe is irrelevant to
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`this factor, nonresponsive to the POPR, and demonstrably false as to the Petition.
`
`Petitioner waited ten months to file this petition, an inexplicably long delay as it
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`first identified the benefit claim and written description challenges at issue in the
`
`IPR in its initial invalidity contentions filed in August 2019 (POPR, 21) but did not
`
`file the Petition until February 2020.
`
`This factor, thus, weighs more heavily in favor of denial than in the 156/157
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`cases. There, the Board found “Petitioner acted diligently and without much
`
`delay” in filing petitions raising newly discovered art eight months after the
`
`complaint and 14 weeks after initial invalidity contentions. 156/157 cases, Paper
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`10 at 11-12 (factor weighed “slightly” in favor of Patent Owner). Here by contrast,
`
`the Petition was filed ten months after the complaint and 25 weeks after
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`Petitioner’s initial invalidity contentions.
`
`Lastly, Petitioner complains that it—like all petitioners—paid the USPTO’s
`
`filing fees. Reply, 7. The Board has never found these omnipresent fees relevant,
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`and Petitioner does not explain why these fees are particularly onerous for the
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`world’s richest company. Petitioner filed the Petition long after NHK became
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`- 6 -
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`
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`precedential, knowing the FWDs would not issue until after trial (Pet., 21). Still,
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`Case IPR2020-00425
`Patent 9,438,550
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`Petitioner brought substantially similar invalidity challenges in both proceedings.
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`Petitioner assumed the risk, and its complaints ring hollow.
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`D. Fintiv Factor #4: There is substantial “overlap between issues
`raised in the petition and in the parallel proceeding.”
`
`This factor also weighs in favor of denial. As Patent Owner has explained,
`
`the grounds and arguments raised here are effectively the same as those raised in
`
`the District Court. POPR, 14-16. Petitioner asserts that it relies on different
`
`references but does not dispute that the Petition is, at bottom, “a collateral attack
`
`on the written description requirement of § 112(a),” the very same challenge raised
`
`in the District Court. Id., 14; Ethicon, Inc. v. Bd. of Regents, IPR2019-00406,
`
`Paper 27, 12 (PTAB Jun. 10, 2020) (factor strongly favored denial even where IPR
`
`raised new reference). Instead, Petitioner ignores the fact that the Petition turns on
`
`the question of written description support and pretends that the Petition is an
`
`obviousness challenge, which it plainly is not.
`
`Petitioner also contends that any overlap has been cured by its alleged
`
`“stipulation.” Reply, 8. But, a moment’s scrutiny reveals that Petitioner’s
`
`stipulation gives up almost nothing and instead reveals Petitioner’s effort to
`
`actually increase the overlap between the District Court Action and the IPRs. This
`
`“stipulation” says: “Apple hereby stipulates that if the [PTAB] institutes … on the
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`- 7 -
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`
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`exact same grounds presented … then Apple will not pursue those same instituted
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`Case IPR2020-00425
`Patent 9,438,550
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`grounds in the … litigation.” Ex. 1045 [Apple Letter] 1. Thus, only the “exact
`
`same” grounds are implicated. Any difference, no matter how trivial, would fall
`
`outside this “stipulation.” Tellingly, Petitioner does not say that any of its
`
`substantially similar litigation grounds would be affected by the “stipulation.”
`
`Petitioner’s empty stipulation should be afforded little or no weight:
`
`Petitioner could have stipulated that it would not pursue any ground
`raised or that could have been reasonably raised in an IPR … A
`broader stipulation of that nature, not at issue here, might better
`address concerns regarding duplicative efforts and potentially
`conflicting decisions in a more substantial way. Likewise, such a
`stipulation might help ensure that an IPR functions as a true
`alternative to litigation … Further still, Petitioner could have
`expressly waived
`in
`the district
`court
`any overlapping
`patentability/invalidity defenses.
`
`Sand Revolution II, LLC v. Continental Intermodal Grp., IPR 2019-01393, Paper
`
`24, 12, n. 5 (PTAB Jun. 16, 2020).
`
`Petitioner’s “stipulation” is, rather, a thinly-veiled attempt to increase the
`
`overlap in art and argument between the District Court and here. It continues: “for
`
`the sake of clarity and to avoid any doubt, if the PTAB declines institution of one
`
`or more IPRs, Apple reserves the right to pursue the grounds of those IPRs in
`
`this litigation. Additionally, Apple reserves its rights to continue to assert all other
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`- 8 -
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`
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`grounds identified in its Notice Regarding Prior Art Reduction. …” Ex. 1045
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`Case IPR2020-00425
`Patent 9,438,550
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`[Apple Letter] 3. Apple, thus, is taking the position—through its “reservation” of
`
`rights—that there is a complete overlap between its litigation grounds and its IPR
`
`grounds, which further favors a denial. Petitioner cannot “reserve” a right unless it
`
`has the right. The “stipulation” removes no grounds and, rather, reveals
`
`Petitioner’s strategy to raise the exact same grounds at trial if institution is denied.
`
`Petitioner also notes that certain claims are challenged in the Petition that are
`
`not asserted. But, Petitioner does not dispute that patent owners face significant
`
`limitations when attempting to reassert a patent against a defendant. POPR, 15,
`
`n.4. Petitioner, moreover, does not argue that these other claims differ from the
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`asserted claims in any significant way, or provide any account of how it could be
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`more than speculatively harmed by their continued existence. These additional
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`claims do not justify institution. POPR, 15-16 (discussing Next Caller, Edward
`
`Lifesciences, and ZTE).
`
`E.
`
`Fintiv Factor #5: It is undisputed that “the petitioner and the
`defendant in the parallel proceeding are the same party.”
`
`Petitioner concedes it is the defendant in the District Court Action. Reply,
`
`9-10. Petitioner speculates that Patent Owner could assert these patents in future
`
`cases, but fails to explain how, even if true, that would be relevant to this factor.
`
`Reply, 9-10. Moreover, Patent Owner is currently litigating just one district court
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`- 9 -
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`
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`action, and only one of the 16 originally asserted patents was ever asserted before.
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`Case IPR2020-00425
`Patent 9,438,550
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`F.
`
`Fintiv Factor #6: “Other circumstances that impact the Board’s
`exercise of discretion, including the merits” favor non-institution.
`
`This factor also favors denial. “Other facts and circumstances may also
`
`impact the Board’s discretion to deny institution” including “considerations
`
`implicated by 35 U.S.C. § 325(d).” Fintiv, 16. The Reply does not dispute that the
`
`Office has already found that the challenged claims to have written description
`
`support, which obviates the challenge to the benefit claim in the Petition. POPR,
`
`Section III. Instead, Petitioner confusingly argues the “present Petition is indeed
`
`particularly strong considering that the primary reference (Fiatal) shares an
`
`identical specification to the ’550 patent itself.” Reply, 10. It does not matter that
`
`Fiatal and the ʼ550 patent specifications are identical, because the Office’s
`
`findings, when these questions “previously were presented to the Office” during
`
`prosecution, 35 U.S.C. § 325(d), confirm that Fiatal is not prior art.
`
`As to the merits, Petitioner makes no attempt to respond to the arguments
`
`raised in the POPR, and merely provides the conclusory assurance that the merits
`
`favor institution. Reply, 10. Requiring Patent Owner to face an IPR trial, ten
`
`months after validity is decided by a jury, would be prejudicial and a tremendous
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`waste of resources.
`
`In sum, the Fintiv factors confirm institution should be denied.
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`- 10 -
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`Dated: June 19, 2020
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`Case IPR2020-00425
`Patent 9,438,550
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`Respectfully submitted,
`
`LOWENSTEIN & WEATHERWAX LLP
`
`By: /Kenneth J. Weatherwax /
`Kenneth J. Weatherwax, Reg. No. 54,528
`Bridget A. Smith, Reg. No. 63,574
`Nathan Lowenstein (pro hac vice pending filing)
`Lowenstein & Weatherwax LLP
`
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`- 11 -
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`CERTIFICATE OF SERVICE
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`Case IPR2020-00425
`Patent 9,438,550
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`I hereby certify that, pursuant to 37 C.F.R. § 42.6(e) and with the agreement
`
`of counsel for Petitioner, true and correct copies of PATENT OWNER’S
`
`SURREPLY and EXHIBITS 2020-2021 are being served electronically on June
`
`19, 2020, to the persons below:
`
`W. Karl Renner
`
`Roberto J. Devoto
`Nicholas Stephens
`
`
`
`
`
`Dated: June 19, 2020
`
`
`IPR39521-0075IP1@fr.com
`PTABInbound@fr.com
`devoto@fr.com
`nstephens@fr.com
`axf-ptab@fr.com
`
`
`By: /Patrick Maloney /
`
`
`
`
`
`
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