`
`UNITED STATES PATENT AND TRADEMARK OFFICE
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`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`
`
`
`Google LLC,
`Petitioner,
`
`v.
`
`WAG Acquisition, L.L.C.,
`Patent Owner.
`
`
`
`IPR2022-01412
`
`U.S. Patent No. 9,742,824 B2
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`
`
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`PETITIONER’S MOTION TO EXCLUDE
`PURSUANT TO 37 C.F.R. § 42.64
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`TABLE OF CONTENTS
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`Page
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`INTRODUCTION .......................................................................................... 1
`I.
`BACKGROUND ............................................................................................ 3
`II.
`III. ARGUMENT .................................................................................................. 5
`A.
`Exhibits 2003, 2004, and 2009 Are Inadmissible Hearsay .................. 5
`1.
`No Hearsay Exception Applies for Exhibits 2003, 2004,
`and 2009 ..................................................................................... 8
`2. Mr. Hoarty Should Not Rely on Exhibits 2003, 2004, and
`2009 under FRE 703 ................................................................ 10
`Exhibit 2008 Is Irrelevant ................................................................... 10
`B.
`If Relevant, Exhibit 2008 Should Be Excluded Under FRE 403 ....... 12
`C.
`IV. CONCLUSION ............................................................................................. 12
`CERTIFICATE OF SERVICE ............................................................................... 14
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`-i-
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`TABLE OF AUTHORITIES
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`Page(s)
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`Cases
`Apple Inc. v. Qualcomm Inc.,
`IPR2018-01249, Paper 27, 51-52 (P.T.A.B. Jan. 6, 2020) ............................... 6, 7
`Asetek Danmark A/S v. CoolIT Sys., Inc.,
`IPR2020-00825, Paper 50, 43-46 (P.T.A.B. Oct. 12, 2021) ................................ 6
`Conoco Inc. v. Dep’t of Energy,
`99 F.3d 387 (Fed. Cir. 1996) ................................................................................ 9
`GAF Materials, LLC v. Kirsch Rsch. and Dev., LLC,
`IPR2021-00192, Paper 45, 62-65 (P.T.A.B. May 24, 2022) .................. 6, 7, 9, 10
`Neste Oil OYJ v. REG Synthetic Fuels, LLC,
`IPR2013-00578, Paper 52, 9 (P.T.A.B. March 12, 2015) .................................... 9
`The Data Co. Techs. Inc. v. Bright Data, Ltd.,
`IPR2022-00135, Paper 51, 80-84 (P.T.A.B. May 31, 2023) ............................ 6, 7
`Unified Patents Inc. v. Sound View Innovations, LLC,
`IPR2018-00599, Paper 50, 51 (P.T.A.B. Sept. 9, 2019) ...................................... 7
`US Endodontics, LLC v. Gold Standard Instruments, LLC,
`PGR2015-00019, Paper 54, 38-42 (P.T.A.B. Dec. 28, 2016) .............................. 8
`Other Authorities
`37 C.F.R.
`§ 42.2 ..................................................................................................................... 5
`§ 42.51(b)(1)(ii) .................................................................................................... 5
`§ 42.53 ................................................................................................................... 5
`§ 42.62(a) .............................................................................................................. 5
`§ 42.64 ................................................................................................................... 1
`§ 42.64(b)(1) ......................................................................................................... 3
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`-ii-
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`TABLE OF AUTHORITIES
`(continued)
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`Page(s)
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`FRE
`401 ............................................................................................................. 2, 10, 11
`403 ................................................................................................................... 2, 11
`703 ................................................................................................................... 2, 10
`801 ............................................................................................................. 2, 5, 6, 8
`802 ................................................................................................................. 2, 5, 7
`803(1)-(23) ............................................................................................................ 8
`804 ......................................................................................................................... 8
`807 ......................................................................................................................... 9
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`-iii-
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`IPR2022-01412
`U.S. Patent No. 9,742,824 B2
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`I.
`
`INTRODUCTION
`Patent Owner WAG Acquisition, L.L.C. (“PO”) repeatedly turns to partial
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`testimony from experts in other matters to purportedly support its arguments in its
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`papers. This testimony is inadmissible hearsay; PO’s exhibits in their entirety are
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`out of court statements from witnesses that Petitioner Google LLC (“Google”) never
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`had an opportunity to cross-examine. Additionally, PO relies on an out of context
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`analysis from an ITC proceeding—which Google did not participate in and did not
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`involve the ʼ824 patent—to bolster an interpretation of a prior art reference that is
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`inconsistent with the actual evidence in this proceeding. The ITC initial
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`determination containing this discussion is irrelevant, as it involved fundamentally
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`different issues and never addressed or analyzed the evidence presented here.
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`Therefore, pursuant to 37 C.F.R. § 42.64 and the Federal Rules of Evidence,
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`Google moves to exclude the following of PO’s exhibits:
`
` Exhibit 2003 – The Walt Disney Co. v. WAG Acquisition, L.L.C.,
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`IPR2022-01228, Ex. 1002 (Declaration of Dr. Henry Houh)
`
` Exhibit 2004 – May 23, 2023 Deposition of Dr. Kevin Jeffay in
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`Amazon.com, Inc. v. WAG Acquisition, L.L.C., IPR2022-01430 and
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`-01433
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`IPR2022-01412
`U.S. Patent No. 9,742,824 B2
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` Exhibit 2008 – In re Certain Fitness Devices, Streaming Components
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`Thereof, and System Containing Same, Inv. No. 337-TA-1265, Initial
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`Determination (ITC Sept. 9, 2022) (CALJ Clark S. Cheney)
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` Exhibit 2009 – In re Certain Fitness Devices, Streaming Components
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`Thereof, and System Containing Same, Inv. No. 337-TA-1265,
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`Evidentiary Hearing - Volume III (ITC March 14, 2022)
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`Exhibits 2003, 2004, and 2009 are a declaration, deposition, and hearing
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`transcript containing testimony of experts not involved in this IPR and from cases
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`not involving Google. These exhibits are inadmissible hearsay in their entirety and
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`should be excluded under Federal Rules of Evidence (“FRE”) 801 and 802.
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`Moreover, PO’s expert in this IPR, W. Leo Hoarty, should not be permitted to rely
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`on these exhibits as the bases of his expert testimony under FRE 703.1
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`1 Google believes it adequately is moving to strike Mr. Hoarty’s reliance on these
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`exhibits generally, but out of an abundance of caution, Google identifies the
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`following specific paragraphs in Mr. Hoarty’s Declaration (Exhibit. 2002) where he
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`cites to the four exhibits Google moves to exclude: ¶ 67 (Exhibit 2003); ¶¶ 65, 66,
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`67 (Exhibit 2004); ¶ 74 (Exhibit 2008); and ¶¶ 54, 65, 66, 67 (Exhibit 2009).
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`IPR2022-01412
`U.S. Patent No. 9,742,824 B2
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`Exhibit 2008 is an Initial Determination from the ITC, which should be
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`excluded under FRE 401 as irrelevant. To the extent Exhibit 2008 is deemed
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`relevant, it should nonetheless be excluded under FRE 403.
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`PO improperly relies on these exhibits in its Patent Owner Response (“POR”)
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`(Paper 11), filed on June 15, 2023 and its Patent Owner Sur-Reply (“PO Sur-Reply”)
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`(Paper 17), filed October 19, 2023.2 Google timely objected to these exhibits in its
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`Objections Under 37 C.F.R. § 42.64(b)(1) to Evidence Served by Patent Owner
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`(Paper 12), filed June 23, 2023.
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`For the reasons detailed below, Exhibits 2003, 2004, 2008, and 2009 should
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`be excluded.
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`II. BACKGROUND
`Exhibit 2003 is the testimony (in a declaration) of Henry Houh in IPR2022-
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`01228. Google is not a party to those IPRs.3 Dr. Houh has not offered testimony in
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`the present IPR—he is not an expert for either Google or PO, or otherwise involved,
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`2 As discussed further below, PO relies on Exhibits 2003, 2004, and 2009 for the
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`truth of the matter asserted in its POR and PO Sur-Reply.
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`3 The parties to IPR2022-01227 and -01228 are petitioners The Walt Disney
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`Company, Disney Streaming Services LLC, Hulu, LLC and Netflix, Inc. and patent
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`owner WAG Acquisition, L.L.C.
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`IPR2022-01412
`U.S. Patent No. 9,742,824 B2
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`in the present IPR,4 and Google has never had an opportunity to question Dr. Houh
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`regarding his testimony in those other proceedings.
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`Exhibit 2004 is the testimony (from deposition) of Kevin Jeffay in IPR2022-
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`01430 and -01433. Again, Google is not a party to those IPRs,5 and Dr. Jeffay is not
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`an expert for Google or PO, or otherwise involved, in the present IPR. In other
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`words, Dr. Jeffay has not offered testimony in the present IPR, and Google has never
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`had an opportunity to question Dr. Jeffay regarding his testimony in those other
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`proceedings.
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`Exhibit 2009 consists of Dr. Jeffay’s testimony from a wholly unrelated
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`matter—it is a hearing transcript containing Dr. Jeffay’s testimony during an ITC
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`evidentiary hearing, which did not involve Google, PO, or the ʼ824 patent (or any
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`related patent). Once again, Google has never had an opportunity to question Dr.
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`Jeffay regarding his testimony in that other proceeding.
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`4 Google’s expert in this IPR is Nathaniel Polish, and, as noted above, PO’s expert
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`in this IPR is W. Leo Hoarty.
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`5 The parties to IPR2022-01430 and -01433 are petitioners Amazon.com, Inc.,
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`Amazon Web Services, Inc., and Amazon.com Services LLC and patent owner
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`WAG Acquisition, L.L.C.
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`IPR2022-01412
`U.S. Patent No. 9,742,824 B2
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`Finally, Exhibit 2008 is ALJ Cheney’s initial determination in the same ITC
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`matter in which Dr. Jeffay opined. However, as noted above, neither Google nor PO
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`were parties to that ITC investigation.6 That ITC investigation also did not involve
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`the ʼ824 patent or any patent related to the ʼ824 patent.
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`III. ARGUMENT
`A. Exhibits 2003, 2004, and 2009 Are Inadmissible Hearsay
`Statements “the declarant does not make while testifying at the current trial or
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`hearing[,]” offered “to prove the truth of the matter asserted in the statement” are
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`hearsay. FRE 801(c). Hearsay is inadmissible absent an exception. FRE 802. The
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`rule against hearsay applies to IPRs. 37 C.F.R. § 42.62(a).
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`In an IPR, in-court statements are “submitted in the form of an affidavit” or a
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`compliant declaration. 37 C.F.R. §§ 42.53, 42.2. This ensures that an opposing
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`party can cross-examine the declarant in the IPR. 37 C.F.R. § 42.51(b)(1)(ii).
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`Testimony, including testimony from other matters, such as IPRs and ITC
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`investigations, which is not subject to cross-examination by the opposing party in an
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`6 The parties in the ITC proceeding were complainants DISH DBS Corporation,
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`DISH Technologies, L.L.C., and Sling TV L.L.C. and respondents iFIT, Inc. f/k/a
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`ICON Health & Fitness, Inc., FreeMotion Fitness, Inc., NordicTrack, Inc., Peloton
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`Interactive, Inc., lululemon athletica, inc., and Curiouser Products Inc.
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`-5-
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`IPR2022-01412
`U.S. Patent No. 9,742,824 B2
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`IPR, is hearsay if offered for the truth of the matter. See GAF Materials, LLC v.
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`Kirsch Rsch. and Dev., LLC, IPR2021-00192, Paper 45, 62-65 (P.T.A.B. May 24,
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`2022) (excluding excerpts from expert declaration from district court from IPR as
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`hearsay); The Data Co. Techs. Inc. v. Bright Data, Ltd., IPR2022-00135, Paper 51,
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`80-84 (P.T.A.B. May 31, 2023) (excluding transcript excerpts from a trial involving
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`PO and a third party as hearsay); Apple Inc. v. Qualcomm Inc., IPR2018-01249,
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`Paper 27, 51-52 (P.T.A.B. Jan. 6, 2020); Asetek Danmark A/S v. CoolIT Sys., Inc.,
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`IPR2020-00825, Paper 50, 43-46 (P.T.A.B. Oct. 12, 2021) (excluding testimony
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`from district court proceeding from IPR as hearsay).
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`Here, Exhibits 2003, 2004, and 2009 are, in their entirety, statements made by
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`Drs. Jeffay (Exhibits 2004 and 2009) and Houh (Exhibit 2003) outside of this
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`proceeding and relied upon by PO to prove the truth of the matter asserted in those
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`exhibits. See FRE 801(c). More specifically, in some instances, PO relies on the
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`statements in these exhibits as alleged evidence of how a person of ordinary skill in
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`the art would understand the Carmel reference (Exhibit 1003) and HTTP.7 See, e.g.,
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`7 To the extent PO argues that it uses these exhibits to show that Dr. Jeffay has taken
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`inconsistent positions, these exhibits are nonetheless irrelevant because Dr. Jeffay is
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`not an expert in this IPR, and his credibility is thus not at issue.
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`-6-
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`IPR2022-01412
`U.S. Patent No. 9,742,824 B2
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`PO Sur-Reply at 11-12 (citing Exhibit 2009); id. at 11 (PO and its expert “explaining
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`referenced detailed testimony by Dr. Jeffay (Amazon’s expert)”); id. at 11
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`(discussing how testimony provided from Dr. Jeffay in Exhibit 2009 “obliterates
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`any ‘inherency assertion’”) (emphasis in original); POR at 33 n.9 (citing “prior
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`testimony of Dr. Kevin Jeffay”). Critically, Google was not a party to any of the
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`other proceedings in which any of this expert testimony was provided and has not
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`had the opportunity to cross-examine Drs. Jeffay and Houh.
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`The Board has previously excluded expert evidence as hearsay under similar
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`circumstances. For example, in GAF Materials, the Board excluded, under FRE
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`802, an expert declaration that patent owner was using to explain how a person of
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`ordinary skill in the art would understand two different processes, where the expert
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`was not a witness in the present IPR. IPR2021-00192, Paper 45 at 62-65; see also
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`The Data Co., IPR2022-00135, Paper 51 at 82 (“We agree with petitioner that prior
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`testimony from another case, which is not subject to cross-examination by the
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`opposing party, is hearsay if offered for the truth of the matter.”); Apple, IPR2018-
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`01249, Paper 27 at 51-52 (“Thus, this testimony is hearsay because Dr. Alpert does
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`not offer the testimony while testifying at the current trial or hearing.”); Unified
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`Patents Inc. v. Sound View Innovations, LLC, IPR2018-00599, Paper 50, 51
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`(P.T.A.B. Sept. 9, 2019) (“We determine that, as set forth by patent owner . . . this
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`-7-
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`IPR2022-01412
`U.S. Patent No. 9,742,824 B2
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`Exhibit is hearsay under [FRE] 801. Indeed, the Exhibit is a declaration containing
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`testimony from a different IPR, offered to prove the truth of the matter, i.e., Acharya
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`was publicly accessible in July 1999[.]”); US Endodontics, LLC v. Gold Standard
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`Instruments, LLC, PGR2015-00019, Paper 54, 38-42 (P.T.A.B. Dec. 28, 2016) (“The
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`declaration in Exhibit 2034 qualifies as hearsay . . . the statements in that declaration
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`were not made while testifying in this proceeding. Instead, the declaration was
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`submitted during ex parte prosecution of another patent application.”).
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`Additionally, these exhibits do not meet the conditions under FRE 801(d) for
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`out of court statements that are not considered hearsay. The statements made in
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`these exhibits were not made by a representative of Google, with authorization from
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`Google, or by Google’s agent or employee; nor has Google adopted any of the
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`statements made in these exhibits. FRE 801(d)(2).
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`Thus, Exhibits 2003, 2004, and 2009 in their entirety are unquestionably
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`hearsay.
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`1.
`
`No Hearsay Exception Applies for Exhibits 2003, 2004, and
`2009
`None of the hearsay exceptions provided in FRE 803, 804, or 807 apply.
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`First, Exhibits 2003, 2004, and 2009 do not satisfy any of the conditions that
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`are set forth in FRE 803(1)-(23).
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`-8-
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`IPR2022-01412
`U.S. Patent No. 9,742,824 B2
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`Second, FRE 804’s exceptions too do not apply because they require a witness
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`to be unavailable. Under FRE 804, a witness is unavailable due to: (1) a testifying
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`exemption from court rules or privilege; (2) refusing to testify despite a court order;
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`(3) lack of memory; (4) declarant death or then-existing infirmity, physical illness,
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`or mental illness; or (5) the declarant’s testimony is not obtainable by process or
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`other reasonable means. FRE 804. None of these circumstances applies here.
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`Third, Rule 807 (the residual hearsay exception) does not apply either because
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`it requires the statement to (1) be supported by sufficient guarantees of
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`trustworthiness after considering the totality of circumstances under which it was
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`made and (2) be more probative on the point for which it is offered than any other
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`evidence that the proponent can obtain through reasonable efforts. FRE 807. The
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`Board has held that the exercise of the residual exception “is to be reserved for
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`‘exceptional cases,’ and is not ‘a broad license on trial judges to admit hearsay
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`statements that do not fall within one of the other exceptions.’” Neste Oil OYJ v.
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`REG Synthetic Fuels, LLC, IPR2013-00578, Paper 52, 9 (P.T.A.B. March 12, 2015)
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`(quoting Conoco Inc. v. Dep’t of Energy, 99 F.3d 387, 392 (Fed. Cir. 1996)). This
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`is not such an exceptional case. See GAF Materials, IPR2021-00192, Paper 45 at
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`65 (“We agree with Petitioner that no [hearsay] exception or exclusion applies in
`
`this case.”).
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`-9-
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`IPR2022-01412
`U.S. Patent No. 9,742,824 B2
`
`
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`Thus, Exhibits 2003, 2004, and 2009 should be excluded from this
`
`proceeding.
`
`2. Mr. Hoarty Should Not Rely on Exhibits 2003, 2004, and 2009
`under FRE 703
`To the extent PO argues that Mr. Hoarty should nonetheless be able to rely on
`
`Exhibits 2003, 2004, and 2009 to form his expert opinions, PO is incorrect. As the
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`Board found in GAF Materials, “opinions of others offered in litigation are not the
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`sort of ‘facts or data’ that experts in the field [] would reasonably rely on in forming
`
`their own opinions.” IPR2021-00192, Paper 45 at 65.
`
`B.
`Exhibit 2008 Is Irrelevant
`PO cites Exhibit 2008, which is ALJ Cheney’s initial determination from an
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`unrelated ITC investigation, in its POR for ALJ Cheney’s purported understanding
`
`of disclosures in the Carmel reference (Exhibit 1003). See, e.g., POR at 33, 35, 51.
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`However, Exhibit 2008 and ALJ Cheney’s discussion of Carmel are irrelevant under
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`FRE 401.
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`The ITC investigation did not involve either PO or Google. And the asserted
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`patents in the ITC investigation are completely unrelated to the ʼ824 patent and have
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`different disclosures and purported inventions. Critically, ALJ Cheney’s discussions
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`of Carmel, which PO cites, are in the context of the limitations of the patents asserted
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`in the ITC investigation. For example, ALJ Cheney’s discussions of Carmel on
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`-10-
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`IPR2022-01412
`U.S. Patent No. 9,742,824 B2
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`pages 175 and 177-78 of the initial determination are in the context of a limitation
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`reciting, “automatically requesting from the video server subsequent portions of the
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`video by requesting for each such portion one of the files from one of the copies
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`dependent upon successive determinations by the media player to shift the playback
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`quality to a higher or lower quality one of the different copies.” EX2008 at 172-73.
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`ALJ Cheney’s remarks about Carmel should thus be properly placed in the context
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`of analyzing whether Carmel anticipated this limitation and are therefore irrelevant
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`to the determination of whether Google’s grounds involving Carmel invalidate the
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`ʼ824 patent.
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`Additionally, while Google asserts Carmel in its grounds in this IPR, and the
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`respondents in the ITC investigation also relied on Carmel as invalidating prior art,
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`the testimony provided by the experts in this case differs from the testimony
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`provided in that case and the relied-upon disclosures from Carmel also differ in many
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`respects. Accordingly, ALJ Cheney’s understanding of Carmel was informed by
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`different evidence from different proceedings in which Google had no opportunity
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`to participate or present arguments. Moreover, ALJ Cheney’s findings, or any
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`understanding of Carmel’s disclosures, are not controlling of this Board.
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`For these reasons, Exhibit 2008 should be excluded under FRE 401.
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`IPR2022-01412
`U.S. Patent No. 9,742,824 B2
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`
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`C.
`If Relevant, Exhibit 2008 Should Be Excluded Under FRE 403
`Even if found to be relevant, Exhibit 2008 should be excluded under FRE 403
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`because it has very limited probative value for the reasons discussed above, and this
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`limited value is substantially outweighed by the danger of confusing the issues,
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`wasting time, and unfair prejudice. As explained above, the context of ALJ
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`Cheney’s discussion of Carmel is critical, and the manner in which PO cites ALJ
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`Cheney’s discussion is confusing and misleading, and it would be a waste of time
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`for Google to have to explain how the differing contexts impact the analysis.
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`Moreover, given that Google never had an opportunity to present evidence or
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`argument in those proceedings, it would be unfairly prejudicial to Google to have to
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`address the errors in those proceedings. For these reasons, Exhibit 2008 should
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`nonetheless be excluded.
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`IV. CONCLUSION
`Based on the foregoing, the Board should exclude Exhibits 2003, 2004, 2008,
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`and 2009.
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`-12-
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`IPR2022-01412
`U.S. Patent No. 9,742,824 B2
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`Dated: November 30, 2023
`
`COOLEY LLP
`ATTN: Patent Group
`1299 Pennsylvania Avenue NW
`Suite 700
`Washington, DC 20004
`Tel: (202) 842-7885
`Fax: (202) 842-7899
`
`
`
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`Respectfully submitted,
`
`
`By:
`/Eamonn Gardner/
`
` Eamonn Gardner
`
` (Reg. No. 63,322)
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`
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`-13-
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`Pursuant to 37 C.F.R. §§42.6(e)(4)(i) et seq., a complete copy of the attached
`PETITIONER’S MOTION TO EXCLUDE PURSUANT TO 37 C.F.R. § 42.64
`is being served via email on the 30th day of November 2023, upon Patent Owner’s
`appointed attorneys of record:
`
`
`CERTIFICATE OF SERVICE
`
`Ronald Abramson
`ron.abramson@listonabramson.com
`M. Michael Lewis
`michael.lewis@listonabramson.com
`Ari J. Jaffess
`ari.jaffess@listonabramson.com
`Gina K. Kim
`gina.kim@listonabramson.com
`LISTON ABRAMSON LLP
`405 Lexington Ave, 46th Floor
`New York, NY 10174
`Telephone: (212) 257-1630
`Facsimile: (914) 462-4175
`
`
`
`
`
`
`
`
`
`Dated: November 30, 2023
`
`COOLEY LLP
`ATTN: Patent Docketing
`1299 Pennsylvania Avenue NW
`Suite 700
`Washington, D.C. 20004
`Tel: (202) 842-7885
`Fax: (202) 842-7899
`
`
`
`
`/Eamonn Gardner/
`Eamonn Gardner
`(Reg. No. 63,322)
`
`
`
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`-14-
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