throbber
Filed on behalf of: Balt USA, LLC
`By: Sheila N. Swaroop
`William O. Adams
`Alexander Zeng
`KNOBBE, MARTENS, OLSON & BEAR, LLP
`2040 Main Street, 14th Floor
`Irvine, CA 92614
`Telephone: 949-760-0404
`Facsimile: 949-760-9502
`Email: BoxMIBAL001LP@knobbe.com
`
`
`
`
`
`
`
`
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________________________
`
`BALT USA, LLC
`Petitioner,
`
`v.
`
`MICROVENTION, INC.
`Patent Owner.
`
`
`
`
`
`Filed: December 4, 2020
`
`
`
`
`
`
`Case No. IPR2020-01259
`U.S. Patent No. 10,076,338
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`PETITIONER’S REPLY TO PRELIMINARY RESPONSE
`
`

`

`TABLE OF CONTENTS
`
`Page No.
`
`STATUS OF THE DISTRICT COURT LITIGATION ..................................... 1
`THE FINTIV FACTORS COUNSEL AGAINST DENIAL OF
`INSTITUTION .................................................................................................... 2
`
`
`
`-i-
`
`

`

`TABLE OF AUTHORITIES
`
`Page No(s).
`
`Apple Inc. v. Fintiv, Inc.,
`IPR2020-00019, Paper 11 (Mar. 20, 2020) .......................................... passim
`Apple Inc. v. Seven Networks, LLC,
`IPR2020-00235, Paper 10 (PTAB July 28, 2020) ......................................... 3
`Church & Dwight Co., Inc. v. Batinkoff,
`No. IPR2020-00168, Paper 11 (PTAB May 15, 2020) ................................. 4
`DivX, LLC v. Netflix, Inc.,
`Case No. 19-1602 PSG, 2020 WL 3026034
`(C.D. Cal. May 11, 2020) .............................................................................. 4
`
`MED-EL Elektromedizinische Geräte Ges.m.b.H. v. Advanced
`Bionics AG,
`IPR2020-00190, Paper 15 (PTAB June 3, 2020) .......................................... 3
`MicroVention, Inc. v. Balt USA, LLC,
`Civil Action No. 8:19-cv-01335-JLS-KES (C.D. Cal.) ........................ passim
`Nanocellect Biomedical, Inc. v. Cytonome/st, LLC,
`No. IPR2020-00551, Paper 19 (PTAB Aug. 27, 2020) ................................. 5
`Nvidia Corp. v. Tessera Advanced Techs., Inc.,
`No. IPR2020-00708, Paper 9 (PTAB Sept. 2, 2020) ..................................... 5
`Samsung Electronics Co., Ltd. v. Dynamics, Inc.,
`IPR2020-00502, Paper 34 (PTAB Aug. 12, 2020) .................................... 4, 5
`
`Sand Revolution II, LLC v. Continental Intermodal
`Group-Trucking LLC,
`IPR2019-01393, Paper 24 (PTAB June 16, 2020) .................................... 4, 5
`VMware, Inc. v. Intellectual Ventures I LLC,
`No. IPR2020-00470, Paper 13 (PTAB Aug. 18, 2020) ................................. 5
`
`-ii-
`
`

`

`TABLE OF AUTHORITIES
`(Cont’d)
`
`Page No(s).
`
`STATUTES
`35 U.S.C. § 316 ................................................................................................... 5
`
`
`
`
`
`
`
`
`
`
`
`
`
`-iii-
`
`

`

`Balt USA, LLC v. MicroVention, Inc.
`IPR2020-01259
`
`TABLE OF EXHIBITS
`
`
`
`
`
`Description
`
`1001
`1002
`1003
`1004
`1005
`
`1006
`
`1007
`
`1008
`
`1009
`
`1010
`1011
`
`1012
`
`1013
`
`U.S. Patent No. 10,076,338
`U.S. Patent Publication No. 2006/0052815 (“Fitz”)
`U.S. Patent No. 6,193,728 (“Ken”)
`Declaration of Marc-Alan Levine
`File History of U.S. Patent No. 10,076,338
`Complaint, Dkt. 1, MicroVention, Inc. v. Balt USA, LLC, No.
`8:19-cv-01335-JLS-KES (C.D. Cal., filed July 8, 2019)
`Summons, Dkt. 8, MicroVention, Inc. v. Balt USA, LLC, No. 8:19-
`cv-01335-JLS-KES (C.D. Cal., filed July 8, 2019)
`Joint Claim Construction Prehearing Statement, Dkt. 31, Mi-
`croVention, Inc. v. Balt USA, LLC, No. 8:19-cv-01335-JLS-KES
`(C.D. Cal., filed July 8, 2019)
`Joint Technology Tutorial for Markman, submitted in MicroVen-
`tion, Inc. v. Balt USA, LLC, No. 8:19-cv-01335-JLS-KES (C.D.
`Cal., filed July 8, 2019)
`Marc-Alan Levine Curriculum Vitae
`Marc-Alan Levine List of Materials Considered
`Balt’s Opening Claim Construction Brief & Supporting Materials,
`Dkt. 33-34, MicroVention, Inc. v. Balt USA, LLC, No. 8:19-cv-
`01335-JLS-KES (C.D. Cal., filed July 8, 2019)
`MVI’s Opening Claim Construction Brief & Supporting Materi-
`als, Dkt. 35, MicroVention, Inc. v. Balt USA, LLC, No. 8:19-cv-
`01335-JLS-KES (C.D. Cal., filed July 8, 2019)
`
`Table of Exhibits, Page 1
`
`

`

`Balt USA, LLC v. MicroVention, Inc.
`IPR2020-01259
`
`
`
`Description
`
`1014
`
`1015
`
`1016
`
`1017
`
`1018
`
`1019
`
`1020
`
`1021
`
`1022
`
`1023
`
`1024
`1025
`1026
`1027
`
`Order Continuing Claim Construction Hearing, Dkt. 41, Mi-
`croVention, Inc. v. Balt USA, LLC, No. 8:19-cv-01335-JLS-KES
`(C.D. Cal., filed July 8, 2019)
`U.S. Patent No. 8,182,506
`Scheduling Order, Dkt. 21, MicroVention, Inc. v. Balt USA, LLC,
`No. 8:19-cv-01335-JLS-KES (C.D. Cal., filed July 8, 2019)
`U.S. Patent No. 7,048,719 (“Monetti”)
`Suzanne R. Morrison, Guglielmi Detachable Coils: An Alterna-
`tive Therapy for Surgically High-Risk Aneurysms, J. NEUROSCI-
`ENCE NURSING, Vol. 29, No. 1, 232-237 (Aug. 1997)
`J.V. Byrne, et al., Treatment by Endovascular Packing with the
`Guglielmi Detachable Coil, in Endovascular Treatment of Intra-
`cranial Aneurysms, 134-165 (1998)
`U.S Patent No. 5,895,385 (“Guglielmi”)
`Cloft, et al., Use of Three-dimensional Guglielmi Detachable
`Coils in the Treatment of Wide-necked Cerebral Aneurysms, AM
`J. NEURORADIOL. 21:1312-1314 (Aug. 2000)
`David Niemann, et al., Anatomically Conformable, Three-Dimen-
`sional, Detachable Platinum Microcoil System for the Treatment
`of Intracranial Aneurysms, AM. J. NEURORADILOGY, 25:813-818
`(May 2004)
`Ferdinand K Hui, et al., A history of detachable coils: 1987-2012,
`J. NEUROVASCULAR SURG. 6:134-138 (2014)
`U.S. Patent No. 6,478,773 (“Gandhi”)
`U.S. Patent Publication No. 2004/0034363 A1 (“Wilson”)
`U.S. Patent Publication No. 2007/0239193 A1 (“Simon”)
`Exhibit Number Not Used
`
`Table of Exhibits, Page 2
`
`

`

`Balt USA, LLC v. MicroVention, Inc.
`IPR2020-01259
`
`
`
`Description
`
`Balt’s Responsive Claim Construction Brief, Dkt. 36, MicroVen-
`tion, Inc. v. Balt USA, LLC, No. 8:19-cv-01335-JLS-KES (C.D.
`Cal., filed July 8, 2019)
`Order Continuing Claim Construction Hearing, Dkt. 41, Mi-
`croVention, Inc. v. Balt USA, LLC, No. 8:19-cv-01335-JLS-KES
`(C.D. Cal., filed July 8, 2019)
`Order Granting Stipulation re Modification of the Pretrial Sched-
`uling Order, Dkt. 44, MicroVention, Inc. v. Balt USA, LLC, No.
`8:19-cv-01335-JLS-KES (C.D. Cal., filed July 8, 2019)
`Order Directing Balt to Notice Motion to Stay, Dkt. 46, Mi-
`croVention, Inc. v. Balt USA, LLC, No. 8:19-cv-01335-JLS-KES
`(C.D. Cal., filed July 8, 2019)
`Order Vacating Claim Construction Hearing, Dkt. 53, MicroVen-
`tion, Inc. v. Balt USA, LLC, No. 8:19-cv-01335-JLS-KES (C.D.
`Cal., filed July 8, 2019)
`Letter Stipulation from William O. Adams regarding ’338 patent
`Dated November 18, 2020
`Email Correspondence from Patent Trial and Appeal Board Dated
`November 24, 2020
`
`1028
`
`1029
`
`1030
`
`1031
`
`1032
`
`1033
`
`1034
`
`
`
`Table of Exhibits, Page 3
`
`

`

`Balt USA, LLC v. MicroVention, Inc.
`IPR2020-01259
`Pursuant to the Board’s November 24, 2020 email (Ex. 1034), Petitioner re-
`
`spectfully submits this supplemental briefing to address the Fintiv factors. Apple
`
`Inc. v. Fintiv, Inc., IPR2020-00019, Paper 11 at 6 (Mar. 20, 2020) (precedential).
`
`STATUS OF THE DISTRICT COURT LITIGATION
`
`In MicroVention, Inc. v. Balt USA, LLC, Civil Action No. 8:19-cv-01335-JLS-
`
`KES (C.D. Cal.) (the “District Court Litigation”), Patent Owner MicroVention, Inc.
`
`(“MicroVention”) asserts infringement of three1 patents, including the ’338 patent
`
`at issue here. Ex. 1006 at 9. All patents are somewhat related in that the ’819 patent
`
`and ’506 patent share a common specification, and, although filed much later with-
`
`out a claim of priority to the ’819 or ’506 patents, the specification of the ’338 patent
`
`largely tracks the earlier patents. Ex. 1012 at 6-7. Compare Ex. 1001 with Ex. 1002.
`
`These three patents do not claim anything novel or nonobvious. This is particularly
`
`true for the ’338 patent, especially when compared to the prior art publication (Ex.
`
`1002) of the earlier filed application to the ’506 patent.
`
`While Patent Owner filed its Complaint on July 8, 2019, the District Court
`
`Litigation is still in its early stages. See Ex. 1006. Due to a crowded docket and
`
`COVID-19 related issues, the case schedule has been amended twice, with the latest
`
`
`1U.S. Patent Nos. 8,182,506 (“’506 patent”), 9,414,819 (“’819 patent”), and
`
`10,076,338 (“’338 patent”).
`
`-1-
`
`

`

`Balt USA, LLC v. MicroVention, Inc.
`IPR2020-01259
`amended scheduling order setting the close of fact discovery for February 26, 2021
`
`and the close of expert discovery for May 14, 2021. Exs. 1029, 1030, 1032. A trial
`
`date has not been set. See Ex. 1030. On August 9, 2020, the District Court ordered
`
`that Petitioner file a motion to stay in view of this IPR petition. Ex. 1031. The
`
`motion to stay is now fully briefed and is scheduled for hearing on January 22, 2021.
`
`Ex. 1032. On September 18, 2020, the District Court vacated the Markman hearing
`
`in view of “Defendant’s motion to stay this action in light of the [pending] IPR Re-
`
`view,” stating it would “reschedule the Claim Construction Hearing if the action is
`
`not stayed.” Ex. 1032. Because the Markman hearing has been indefinitely vacated,
`
`the remainder of the schedule and the trial date remain uncertain.
`
`THE FINTIV FACTORS COUNSEL AGAINST DENIAL OF INSTITUTION
`
`Fintiv Factor #1: Patent Owner’s claim that “[a] stay is unlikely” is pure
`
`conjecture. Petitioner filed its Court-ordered motion to stay on August 18, 2020,
`
`well before MicroVention filed its Patent Owner Preliminary Response (“POPR”).
`
`See Ex. 1031, Ex. 1032. The District Court noted that any rescheduled Markman
`
`date may not be necessary, depending on the outcome of the motion to stay. See Ex.
`
`1032. In view of the pending stay motion, and the Court’s suspension of Markman
`
`deadlines until resolution of that motion, this factor weighs in favor of institution.
`
`Fintiv Factor #2: While acknowledging that a trial date has not been set,
`
`Patent Owner still argues, without basis, that “the District Court Action will resolve
`
`-2-
`
`

`

`Balt USA, LLC v. MicroVention, Inc.
`IPR2020-01259
`the validity and infringement issues concerning the ’338 Patent and the other patents
`
`at issue in the District Court Action, at least five months before a final written deci-
`
`sion in this inter partes review is due.” POPR at 35. That conjecture is divorced
`
`from the reality of the District Court Litigation. The District Court has already
`
`amended the case schedule case twice, and with the uncertainty surrounding the cur-
`
`rently vacated Markman deadlines and the on-going COVID-19 pandemic, the pos-
`
`sibility of additional extensions cannot be excluded. Exs. 1029, 1030, 1032; see also
`
`Apple Inc. v. Seven Networks, LLC, IPR2020-00235, Paper 10 at 8 (PTAB July 28,
`
`2020) (“[T]he coronavirus pandemic already has disrupted the trial date once, and
`
`the situation continually evolves.”). Patent Owner apparently bases its trial date
`
`prediction on the currently scheduled Final Pre-Trial Conference date. POPR at 34-
`
`35. However, that date was based on a Markman hearing date that was first contin-
`
`ued to September 22, 2020, Ex. 1016, and now has been subsequently vacated. A
`
`Markman hearing still has not occurred, nor is it even scheduled at this point. Exs.
`
`1030, 1032. Thus, it is more likely that the District Court grants Balt’s motion to
`
`stay or further extends the schedule rather than scheduling a trial in 2021.
`
`Regardless of the uncertainty regarding COVID-19, and contrary to Patent
`
`Owner’s hypothetical projections, a trial date has not been set and this factor
`
`weighs heavily in favor of institution. See MED-EL Elektromedizinische Geräte
`
`Ges.m.b.H. v. Advanced Bionics AG, IPR2020-00190, Paper 15 at 9-12 (PTAB June
`
`-3-
`
`

`

`Balt USA, LLC v. MicroVention, Inc.
`IPR2020-01259
`3, 2020) (instituting IPR because trial date less than one month before Final Written
`
`Decision and Markman hearing was delayed twice).
`
`Fintiv Factor #3: The current deadline to complete fact discovery is February
`
`26, 2021, and the deadline to complete expert discovery is nearly three months after
`
`that. Ex. 1030. Although some discovery has occurred, there is “significantly more
`
`work left to be done.” DivX, LLC v. Netflix, Inc., Case No. 19-1602 PSG (DFMx),
`
`2020 WL 3026034, at *2 (C.D. Cal. May 11, 2020). The parties have not completed
`
`their document production. Moreover, if the District Court reschedules the Mark-
`
`man deadlines and eventually issues a Markman Order, there will much more left to
`
`do in this case to complete fact and expert discovery. Thus, this factor weighs in
`
`favor of institution. Fintiv, Paper 11 at 10; see also Church & Dwight Co., Inc. v.
`
`Batinkoff, No. IPR2020-00168, Paper 11 at 15 (PTAB May 15, 2020) (finding third
`
`factor weighs against denial because “the district court has not yet held a claim con-
`
`struction hearing or issued a claim construction order.”); see also Sand Revolution
`
`II, LLC v. Continental Intermodal Group-Trucking LLC, IPR2019-01393, Paper 24
`
`at 11 (PTAB June 16, 2020) (“Also, we recognize that much work remains in the
`
`district court case as it relates to invalidity…: fact discovery is still ongoing, expert
`
`reports are not yet due, and substantive motion practice is yet to come.”).
`
`Fintiv Factor #4: Petitioner seeks review of all claims of the ’338 patent, not
`
`merely those at issue in the concurrent litigation. Samsung Electronics Co., Ltd. v.
`
`-4-
`
`

`

`Balt USA, LLC v. MicroVention, Inc.
`IPR2020-01259
`Dynamics, Inc., IPR2020-00502, Paper 34 at 12 (PTAB Aug. 12, 2020) (finding
`
`fourth factor weighs in favor of institution when the petition sought review of all
`
`claims, not merely those at issue in the concurrent litigation). Moreover, Petitioner
`
`has provided Patent Owner with a stipulation that, if the Petition is instituted, they
`
`will not pursue in the District Court Litigation any instituted ground that was raised
`
`in the Petition. Ex. 1033. Thus, there will be no overlap of invalidity issues between
`
`the District Court litigation and this IPR. This factor weighs in favor of institution.
`
`See VMware, Inc. v. Intellectual Ventures I LLC, No. IPR2020-00470, Paper 13 at
`
`19-20 (PTAB Aug. 18, 2020); Sand Revolution II, Paper 24 at 11-12; Nanocellect
`
`Biomedical, Inc. v. Cytonome/st, LLC, No. IPR2020-00551, Paper 19 at 21-24
`
`(PTAB Aug. 27, 2020); Nvidia Corp. v. Tessera Advanced Techs., Inc., No.
`
`IPR2020-00708, Paper 9 at 16-17 (PTAB Sept. 2, 2020).
`
`Fintiv Factor #5: Petitioner and Patent Owner are the same parties in both
`
`proceedings, but the Board has repeatedly declined to exercise its discretion to deny
`
`institution. See VMWare, Inc., Paper 13 at 20-21; Samsung Elecs., Paper 34 at 13.
`
`Fintiv Factor #6: Contrary to Patent Owner’s unsupported allegations
`
`(POPR at 37-38), Petitioner did not “delay” in filing its Petition, nor does Petitioner
`
`seek to “stall resolution of the issues in the District Court Action.” Indeed, Balt
`
`timely filed its Petition before the statutory deadline, see U.S.C. § 316(a)(11), and
`
`as soon as reasonably possible in view of the circumstances surrounding COVID-19
`
`-5-
`
`

`

`Balt USA, LLC v. MicroVention, Inc.
`IPR2020-01259
`and the concurrent District Court Litigation. In that litigation, a Markman hearing
`
`was originally scheduled for May 5, 2020 (see supra § Fintiv Factor #2), and Peti-
`
`tioner expected a claim construction decision soon thereafter and well before the
`
`statutory deadline to bring this Petition. A Markman decision from the District Court
`
`could have potentially been beneficial to the Board here. However, shortly before
`
`the Markman hearing was scheduled to occur, the District Court continued the hear-
`
`ing until July 21, 2020. Ex. 1029. After that continuation, Petitioner finished pre-
`
`paring, and timely filed, this Petition. Thus, there was no “delay” by Petitioner.
`
`Likewise, Patent Owner’s argument that Petitioner seeks to “stall resolution
`
`of the issues in the District Court Action” lacks merit. Balt filed the Petition because
`
`the ’338 patent is invalid. Regardless of whether the District Court Litigation is
`
`stayed, the claims of the ’338 patent should be cancelled. In addition, should the
`
`Petition be instituted, there will be no overlapping invalidity issues between the Pe-
`
`tition and the District Court Litigation in view of Petitioner’s stipulation (see supra
`
`§ Fintiv Factor #4). Finally, because the trial date is not set in the District Court
`
`Litigation (see supra § Fintiv Factor #1), Patent Owner’s argument that “the inter
`
`partes review, if instituted, would result in a final written decision only after the
`
`overlapping issues have been resolved by a district court” (POPR at 38) is incorrect.
`
`In attempting to address the Petition’s merits, Patent Owner inaccurately de-
`
`scribes the prosecution history of the ’338 patent and the parent application. Patent
`
`-6-
`
`

`

`Balt USA, LLC v. MicroVention, Inc.
`IPR2020-01259
`Owner incorrectly states that the Petition “relies upon the same prior art that was
`
`previously before, and substantively evaluated by, the Office during prosecu-
`
`tion of the ’338 Patent and its parent.” POPR at 37-39 (emphasis added). But the
`
`Office did not “substantively evaluate[]” Petitioner’s cited combination during the
`
`’338 patent’s prosecution. See Ex. 1005. That the Office evaluated the prior art in
`
`a “parent” to the ’338 patent is of no merit, especially since the claims in that appli-
`
`cation are substantively different from the challenged claims here. Compare EX
`
`2001 with Exs. 1001, 1005. In its POPR, Patent Owner omitted highly relevant in-
`
`formation regarding the parent application’s file history. For example, after the ex-
`
`aminer in the parent application rejected the pending claims as obvious over Fitz in
`
`view of Ken, Patent Owner amended and cancelled the pending claims in an attempt
`
`to overcome the rejection. See EX 2001 at 214 (“Claims 23 and 24 [which depend
`
`from claim 22] have been rejected as being unpatentable over Fitz in view of…Ken).
`
`Claim 23 has been cancelled in light of the amendment to claim 22.”) Patent Owner
`
`also failed to mention that no claims issued from that abandoned application. See
`
`EX 2001 at 399-400. The merits of the Petition are very strong for the reasons stated
`
`in the Petition. Patent Owner’s POPR, when appropriately considered with the pros-
`
`ecution history of the abandoned parent application, do not suggest otherwise.
`
`-7-
`
`

`

`Balt USA, LLC v. MicroVention, Inc.
`IPR2020-01259
`
`
`Respectfully submitted,
`
`
`
`KNOBBE, MARTENS, OLSON & BEAR, LLP
`
`
`Dated: December 4, 2020
`
`
`
`
`
`By: /William O. Adams/
`Sheila N. Swaroop (Reg. No. 53,658)
`William O. Adams (Reg. No. 68,306)
`Alexander Zeng (Reg. No. 73,564)
`Customer No. 20,995
`
`Attorneys for Petitioner
`Balt USA, LLC
`(949) 760-0404
`
`-8-
`
`

`

`Balt USA, LLC v. MicroVention, Inc.
`IPR2020-01259
`
` CERTIFICATE OF SERVICE
`
`
`
`I hereby certify that a true and correct copy of the foregoing PETITIONER’S
`
`REPLY TO PRELIMINARY RESPONSE is being served on December 4, 2020,
`
`via email pursuant to 37 C.F.R. § 42.6(e) per agreement of the parties, to counsel for
`
`Brian Nash
`Pillsbury Winthrop Shaw Pittman LLP
`401 Congress Avenue, Suite 1700
`Austin, TX 78701
`Direct Line: (512) 580-9629
`email: brian.nash@pillsburylaw.com
`
`email: Docket_ip@pillsburylaw.com.
`
`
`Petitioners at the addresses below.:
`
`Evan Finkel
`Pillsbury Winthrop Shaw Pittman LLP
`725 South Figueroa Street, Suite 2800
`Los Angeles, CA 90017-5406
`Direct Line: (213) 488-7307
`email: evan.finkel@pillsburylaw.com
`
`Richard K. Yoon
`Associate General Counsel & Sr.
`Director of Intellectual Property
`MicroVention, Inc.
`35 Enterprise
`Aliso Viejo, California 92656
`Phone: (714) 247-8142
`email:
`richard.yoon@microvention.com
`
`
`
`Dated: December 4, 2020
`
`
`
`33801743
`
`
`
`
`By: /William O. Adams/
`Sheila N. Swaroop (Reg. No. 53,658)
`William O. Adams (Reg. No. 68,306)
`Alexander Zeng (Reg. No. 73,564)
`Customer No. 20,995
`
`Attorneys for Petitioner
`Balt USA, LLC
`(949) 760-0404
`
`
`-9-
`
`

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