AGIS Software Development LLC

Patent Trials and Appeals Board

Nov 25, 2020

IPR2020-00873 (P.T.A.B. Nov. 25, 2020)

Trials@uspto.gov Paper: 16
571-272-7822 Date: November 25, 2020

UNITED STATES PATENT AND TRADEMARK OFFICE

BEFORE THE PATENT TRIAL AND APPEAL BOARD

GOOGLE LLC, SAMSUNG ELECTRONICS CO., LTD., and SAMSUNG
ELECTRONICS AMERICA, INC.,
Petitioner,
v.
AGIS SOFTWARE DEVELOPMENT, LLC,
Patent Owner.

IPR2020-00873
Patent 9,820,123 B2

Before TREVOR M. JEFFERSON, CHARLES J. BOUDREAU, and
FREDERICK C. LANEY, Administrative Patent Judges.

JEFFERSON, Administrative Patent Judge.

DECISION
Denying Institution of Inter Partes Review
35 U.S.C. § 314

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I. INTRODUCTION
Google LLC, Samsung Electronics Co., Ltd., and Samsung
Electronics America, Inc. (collectively, “Petitioner”) filed a Petition for inter
partes review of claims 1–48 (the “challenged claims”) of U.S. Patent
No. 9,820,123 B2 (Ex. 1001, “the ’123 patent”). Paper 5 (“Pet.”). Patent
Owner, AGIS Software Development LLC, filed a Preliminary Response.
Paper 12 (“Prelim. Resp.”). Pursuant to our authorization for supplemental
briefing, Petitioner filed a Reply to Patent Owner’s Preliminary Response,
and Patent Owner filed a Sur-reply. Paper 13 (“Pet. Reply”); Paper 14 (“PO
Sur-reply”); see Ex. 1037 (authorizing the parties’ reply and sur-reply).
Under 35 U.S.C. § 314(a), an inter partes review may not be instituted
unless the information presented in a petition and any preliminary response
“shows that there is a reasonable likelihood that the petitioner would prevail
with respect to at least 1 of the claims challenged in the petition.” Further,
the Board has discretion to deny a petition even when a petitioner meets that
threshold. Id.; see, e.g., Cuozzo Speed Techs., LLC v. Lee, 136 S. Ct. 2131,
2140 (2016) (“[T]he agency’s decision to deny a petition is a matter
committed to the Patent Office’s discretion.”); NHK Spring Co. v. Intri-Plex
Techs., Inc., IPR2018-00752, Paper 8 (PTAB Sept. 12, 2018) (precedential)
(“NHK Spring”).
Having considered the parties’ submissions, and for the reasons
explained below, we exercise our discretion under 35 U.S.C. § 314(a) to
deny institution of inter partes review.
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II. BACKGROUND
A. Related Proceedings
The parties identify various judicial or administrative matters that
would affect or be affected by a decision in this proceeding. Pet. 74–75.
Paper 7, 1–5 (Patent Owner’s Mandatory Notices). Of particular relevance
for our Decision, the parties identify that the ’829 patent is the subject of the
following pending civil actions: AGIS Software Dev., LLC v. Waze Mobile
Ltd., No. 2:19-cv-00369 (E.D. Tex.); AGIS Software Dev., LLC v. Google
LLC, No. 2:19-cv-00361 (E.D. Tex.); and AGIS Software Dev., LLC v.
Samsung Elecs. Co., Ltd., No. 2:19-cv-00362 (E.D. Tex.). Pet. 73; Paper 7,
4. The parties inform us that these three civil actions were consolidated on
February 20, 2020, with the case involving Google as the lead case (referred
to below as “the parallel District Court proceeding”). Pet. 73; Prelim. Resp.
3.
B. The ʼ123 Patent
The ’123 patent generally discloses a wireless handheld device “used
in conjunction with a remote Server . . . to quickly establish a
communication network of cell phone participants having a common
temporary ad hoc network using mobile wireless communication devices.”
Ex. 1001, 1:40–46. The mobile devices on ad hoc network can “either
broadcast to a group or selectively transmit to each of the other [wireless
devices] . . . its GPS position and status.” Id. at 2:57–3:14.
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C. Illustrative Claim
Petitioner challenges all claims, claims 1–48, of the ’123 patent.
Claims 1, 14, 23, and 36 are independent. Independent claim 1 is
illustrative.
1. A computer-implemented method comprising:
performing, by a first device:
receiving a message sent by a second device, wherein the
message relates to joining a group;
based on receipt of the message sent by the second device,
sending first location information to a first server and receiving
second location information from the first server, the first
location information comprising a location of the first device, the
second location information comprising one or more locations of
one or more respective second devices included in the group;
sending, from the first device to a second server, a request
for georeferenced map data;
receiving, from the second server, the georeferenced map
data;
presenting, via an interactive display of the first device, a
georeferenced map and one or more user-selectable symbols
corresponding to one or more of the second devices, wherein the
symbols are positioned on the georeferenced map at respective
positions corresponding to the locations of the second devices
represented by the symbols, and wherein the georeferenced map
data relate positions on the georeferenced map to spatial
coordinates; and
identifying user interaction with the interactive display
selecting a particular user-selectable symbol corresponding to a
particular second device and user interaction with the display
specifying an action and, based thereon, using an Internet
Protocol to send data to the particular second device,
wherein identifying the user interaction selecting the
particular user-selectable symbol comprises:
detecting user selection of a portion of the interactive
display corresponding to a position on the georeferenced map,
and
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identifying the particular user-selectable symbol based, at
least in part, on coordinates of the selected position, comprising:
searching a set of symbols for a symbol located nearest to
the coordinates of the selected position, wherein the set of
symbols includes the user-selectable symbols corresponding to
the second devices in the group, and wherein data associated with
the set of symbols include coordinates of portions of the display
corresponding to the symbols in the set, and
based on a result of searching the set of symbols,
identifying the particular user-selectable symbol as the symbol
located nearest to the coordinates of the selected position,
wherein the particular user-selectable symbol corresponds to the
particular second device.

Ex. 1001, 14:59–15:45.
D. Asserted Ground of Unpatentability
The information presented in the Petition sets forth the following
proposed grounds of unpatentability for the challenged claims of the ’123
Patent (Pet. 6):
Claim(s) Challenged 35 U.S.C. §1 Reference(s)/Basis
1–48 103 ’724 patent,2 Borghei3
Petitioner relies on the Declaration of David Hilliard Williams to
support this contention (Ex. 1003, “Williams Dec.”).

1 The Leahy-Smith America Invents Act, Pub. L. No. 112-29, 125 Stat. 284
(September 16, 2011) (“AIA”), included revisions to 35 U.S.C. §103 that
became effective on March 16, 2013. Because the ’123 patent issued from
an application filed before March 16, 2013, we apply the pre-AIA version of
the statutory basis for unpatentability.
2 U.S. Patent No. 7,630,724 B2, issued Dec. 8, 2009 (Ex. 1005, “the ’724
patent”).
3 U.S. Patent App. Publication No. 2012/0008526 A1, published Jan. 12,
2012 (Ex. 1014, “Borghei”).
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III. PRELIMINARY MATTERS
Patent Owner contends we should exercise our discretion under
35 U.S.C. § 314(a) to deny institution of inter partes review. Prelim.
Resp. 3–13; PO Sur-reply 1–4. Patent Owner contends that “[t]he
circumstances of the parallel District Court proceeding necessitate denial of
the Petition under the Board’s precedent, as every factor considered in
relation to efficiency, fairness, and the merits supports denial.” Prelim.
Resp. 3 (citing Apple Inc. v. Fintiv, Inc., IPR2020-00019, Paper 11 (PTAB
Mar. 20, 2020) (precedential) (“Fintiv”)). According to Patent Owner,
“institution of this proceeding would not be consistent with the objective of
the AIA to ‘provide an effective and efficient alternative to District Court
litigation.’” Id. at 8 (quoting NHK Spring, Paper 8 at 20).
After Patent Owner filed its Preliminary Response, we authorized the
parties to submit supplemental briefing on the issue of discretionary denial
under 35 U.S.C. § 314(a). Ex. 1037. The parties addressed further the
factors set forth in Fintiv, which provides several factors that balance
considerations of system efficiency, fairness, and patent quality when a
patent owner raises an argument for discretionary denial due to the advanced
state of a parallel proceeding. Fintiv, Paper 11 at 5–6. These factors are:
1. whether the court granted a stay or evidence exists that one
may be granted if a proceeding is instituted;
2. proximity of the court’s trial date to the Board’s projected
statutory deadline for a final written decision;
3. investment in the parallel proceeding by the court and the
parties;
4. overlap between issues raised in the petition and in the
parallel proceeding;
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5. whether the petitioner and the defendant in the parallel
proceeding are the same party; and
6. other circumstances that impact the Board’s exercise of
discretion, including the merits.
Id.
We now consider these factors to determine whether we should
exercise discretion to deny institution under 35 U.S.C. § 314(a). “[I]n
evaluating the factors, the Board takes a holistic view of whether efficiency
and integrity of the system are best served by denying or instituting review.”
Id. at 6.
A. Fintiv Factor 1: Stay in the Underlying Litigation
Petitioner contends the first Fintiv factor “favors institution because
Judge Gilstrap commonly grants stays after institution of an IPR” and that it
intends to seek a stay now that the Petition has been filed. Pet. 71–72 (citing
Uniloc USA, Inc. v. Google, Inc., 2:17-cv-00231-JRG, Order (E.D. Tex.
Oct. 3, 2017); Intellectual Ventures II LLC v. BITCO Gen. Ins. Corp., 6:15-
cv-59, Memorandum Opinion and Order (E.D. Tex. May 12, 2016);
Memsmart Semiconductor Corp. v. AAC Techs., 2:14-CV-1107-JRG, Order
(E.D. Tex. July 10, 2015); Image Processing Techs. LLC v. Samsung Elecs.
Co., No. 2:16-cv-505-JRG, Order (E.D. Tex. Oct. 25, 2017)). Petitioner
notably, however, fails to provide any analysis of these cited cases to
demonstrate that the facts presented here are analogous to those leading
Judge Gilstrap to determine a stay was appropriate. Patent Owner counters
that Petitioner’s “motion for a stay has been denied,” although a renewed
motion will be permitted if we grant institution of inter partes review.
Prelim. Resp. 11–12. Patent Owner contends, however, that any renewed
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motion by Petitioner for a stay of the parallel district court proceedings will
likely be denied. Id. at 12–13. This is so, Patent Owner argues, because, by
the time the District Court is able to hear such a motion, the case will have
developed to the later stages of the proceedings. See id. Furthermore,
Patent Owner argues that because “the Petitioners . . . cop[ied] this Petition
from previous filings, their delay is likely to weigh heavily against them.”
Id. at 12 (citing Intellectual Ventures v. FedEx et al., No. 2:16-cv-00980-
JRG, Dkt. 141 at 4-5 (E.D. Tex. Oct. 24, 2017)).4 Given the District Court’s
apparent willingness to reconsider a motion to stay if we grant institution of
inter partes review, but also considering the later stage of the district court
proceeding, with trial scheduled to begin in a little over four months, we
view the first Fintiv factor, on balance, as neutral in determining whether to
exercise discretion to deny institution.
B. Fintiv Factor 2: Trial Date in the Underlying Litigation
The district court trial date in the parallel litigation is set for April 5,
2021. Ex. 2004. In the Order setting this date, it further states that the date
“cannot be changed without showing good cause,” which “is not shown
merely by indicating that the parties agree that the deadline should be
changed.” Id. at 5 (emphasis omitted). A trial beginning on that date would

4 Patent Owner also argues that “Petitioners will already have filed their
‘expedited summary judgment’ motion on the sufficiency of the
incorporation by reference statement in the ‘123 Patent and its ancestors,”
but there is no evidence that this has occurred. Prelim. Resp. 13. Petitioner
represent to the contrary that “no such motion is ‘imminent’ as [Patent
Owner] suggests.” Pet. Reply 1–2. We find this argument by Patent Owner
to be speculative and thus give it no weight.
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be completed about seven months before a final written decision would be
due in this proceeding.
Although the trial date is set by an Order of the District Court that
requires “good cause” to be changed, Petitioner contends that we should
consider that date to be “highly uncertain.” Pet. 72. This is so, according to
Petitioner, because it has filed motions to dismiss the case for improper
venue. See id. Patent Owner counters by noting that Petitioner does not
“contest that the proximity of the trial favors denial of institution” and
asserts that Petitioner’s contention regarding the “uncertainty” of the trial
date “is based on conclusory assumptions.” Prelim. Resp. 8. Patent Owner
argues that Petitioner’s reliance on its motion to dismiss to establish
uncertainty is nevertheless undermined by the fact that “Judge Gilstrap has
since denied [Petitioner’s] motion to transfer at least one [other] case
concerning the same accused products” at issue in the parallel litigation
between the parties in this proceeding. Id. at 8–9 (citing Personalized Media
Commc’ns, LLC v. Google LLC, 2:19-cv-00090-JRG, Dkt. No. 291 (E.D.
Tex. Jul. 30, 2020)).
On the record before us at this time, the only persuasive facts that we
have regarding the proximity of the court’s trial date to the Board’s
projected statutory deadline for a final written decision is an Order by the
District Court that sets trial for April 5, 2021, which will require “good
cause” to be changed, and our projected statutory deadline, which would be
toward the end of November 2021. While we appreciate that the trial date is
susceptible to change if and when the District Court determines good cause
exists to do so, we decline to speculate whether such a contingency will
occur. Instead, we must base our evaluation on the existing facts supported
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by the evidence of record. This factor, therefore, significantly favors the
exercise of discretionary denial.
C. Fintiv Factor 3: Investment by the Court and the Parties
in the Underlying Litigation
In the Petition, Petitioner contends that the parallel litigation “is still at
its early stages” and that neither the District Court nor the parties have
invested significant resources. Pet. 72–73. Patent Owner counters by
arguing that, by the time this Institution Decision is due, the parties will have
completed claim construction proceedings, exchanged infringement and
invalidity contentions, and conducted substantial discovery. Prelim. Resp.
10; see also Ex. 2004. In addition, Patent Owner contends, “Petitioners also
fail to justify their delay in bringing this proceeding, which is largely copied
from other Petitions filed in 2018.” Prelim. Resp. 11 (citing Apple Inc. v.
AGIS Software Dev. LLC, IPR2018-00819, Paper 1 (PTAB March 22,
2018); Google LLC v. AGIS Software Dev. LLC, IPR2018-01086, Paper 2
(PTAB May 15, 2018)). Patent Owner argues that, despite Petitioner
“undisputedly know[ing] of the[] grounds [asserted in the Petition] since the
outset of the [parallel] litigation,” “[t]hey fail to articulate any justification
for their delay,” which has “further ensured that the parties would continue
to invest in the District Court Litigation through trial.” Id. at 11. In its
Reply, Petitioner notably does not dispute Patent Owner’s contentions
regarding the time and resources that will have been invested in the parallel
litigation by the time of this Decision, nor does it provide any explanation
why it took over seven months to file a petition alleging grounds of
unpatentability that are significantly similar to earlier petitions filed.
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It appears undisputed on the record before us that the parties have
invested a significant amount of work related to the ’123 patent in
preparation for trial, including claim construction, fact discovery, and expert
discovery. See Ex. 2002; Ex. 2003. Some of this invested effort has
relevance to issues that would arise in this proceeding and thus weighs
toward exercising discretion to deny institution, but its weight is lessened
without any evidence that the district court has issued any orders related
specifically to the patent at issue in the Petition. See Fintiv, Paper 11 at 10
(“If, at the time of the institution decision, the district court has not issued
orders related to the patent at issue in the petition, this fact weighs against
exercising discretion to deny institution under NHK.”).
For this factor, however, we also consider the timing of the Petition
and, “notwithstanding that a defendant has one year to file a petition, it may
impose unfair costs to a patent owner if the petitioner, faced with the
prospect of a looming trial date, waits until the district court trial has
progressed significantly before filing a petition at the Office.” Fintiv,
Paper 11 at 11. To assist with this evaluation, the Board asks clearly for
Petitioner to “explain [the] facts relevant to timing” to show the
reasonableness of a delayed filing of the Petition. Id. Petitioner provides no
explanation here.
The absence of any reasonable explanation for the delay in filing the
Petition is particularly problematic in this case because there is significant
overlap between the subject matter and alleged grounds of unpatentability
found in the Petition and those petitions previously filed against U.S. Patent
9,467,838, a parent of the ’123 patent. See Apple Inc. v. AGIS Software Dev.
LLC, IPR2018-01471, Paper 1 (PTAB July 31, 2018); Google LLC v. AGIS
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Software Dev. LLC, IPR2018-01086, Paper 2 (PTAB May 15, 2018). The
Petitioner is also challenging the patentability of every claim in the ’123
patent, which suggests that there was no need for Petitioner to delay filing
until Patent Owner identified which specific claims of the ’123 patent were
being asserted. When “the evidence shows that the petitioner[s] did not file
the petition expeditiously . . . or even if the petitioner cannot explain the
delay in filing its petition,” we weigh this factor toward exercising discretion
to deny institution. Fintiv, Paper 11 at 11–12. Because the evidence shows
that Petitioner had everything it needed to file the Petition much earlier in
the parallel district court proceedings and because Petitioner offers no
explanation for why the filing was delayed, we find the timing of the
Petition weighs heavily toward exercising discretion to deny institution.
Therefore, weighing all of the above considerations, this factor
significantly favors the exercise of discretionary denial.
D. Fintiv Factor 4: Overlap Between Issues Raised in the Petition and
Underlying Litigation
Petitioner contends “[f]actor 4 favors institution because this petition
challenges all claims in the ’123 patent whereas the district court will (at
most) decide the patentability of only a subset of the challenged claims.”
Pet. 73. However, for the claims in common, Patent Owner correctly notes
that “Petitioners do not contest that they argue the exact same grounds for
invalidity in the District Court Litigation.” Prelim. Resp. 6. In their Reply,
Petitioner argues that any weight given to the overlapping issues is
eliminated because it “ha[s] offered a conditional stipulation to not rely on
the Petition’s prior-art grounds in the district-court litigation if the PTAB
grants institution here.” Pet. Reply 2–3 (citing Ex. 1038). Patent Owner
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disagrees that Petitioner’s “conditional stipulation” cures the inefficiency of
the Board considering the arguments in the Petition and identifies as support
the Petitioner’s express reservation of the right “to argue the central issue of
this petition––the priority date of the ’123 Patent––in District Court.” PO
Sur-reply 2 (citing Pet. Reply 3).
After considering the parties’ arguments and the record before us, we
determine that substantial overlap exists between the issues raised in the
Petition and the underlying litigation. Regarding the differences in the
claims challenged here and in the district court, “if a petition involves the
same prior art challenges but challenges claims in addition to those that are
challenged in the district court, it may still be inefficient to proceed because
the district court may resolve validity of enough overlapping claims to
resolve key issues in the petition.” Fintiv, Paper 11 at 13. The Petition
shows that substantial overlap exists between Petitioner’s arguments and
evidence for the unpatentability of the claims in the ’123 patent; for
example, the Petition groups and addresses all of the independent claims
together, as well as several of the independent claims. See, e.g., Pet. 22–70.
As such, the resolution of the claims elected in the district court will likely
resolve validity of enough overlapping claims to resolve the key issues
presented by the Petition. Notably, Petitioner does not offer any explanation
for why the Petition includes materially different grounds, arguments, and/or
evidence than those presented in the district court. Thus, although the
challenged claims asserted in this proceeding may not be identical to those
that the parties elect to pursue at trial in the underlying litigation, the
differences do not appear to be meaningful in this case.
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Nor are we persuaded that Petitioner’s proposed “conditional
stipulation” alleviates the concerns of potential inefficiencies and the
possibility of conflicting decisions. Petitioner’s proposed stipulation is
ambiguous. See Ex. 1038. It states, “Petitioners will not pursue in their
current district court proceedings . . . any of the same prior art grounds
presented in an instituted IPR petition(s),” but expressly “preserve[s] the
right to make arguments regarding the priority date of [Patent Owner’s]
asserted patents in the district court proceedings.” Id. We note, initially,
that the stipulation does not appear to limit Petitioner from relying on the
prior art asserted in the Petition, but instead limits the waiver to the specific
grounds asserted in the Petition. It is thus unclear whether the scope of the
stipulation would actually limit Petitioner’s ability to rely on the prior art in
the related district court proceedings in a meaningful way to avoid
duplicative efforts and potentially conflicting decisions. For example, it
appears Petitioner could still rely on the same prior art for many of the same
claim elements so long as it also includes another prior art reference in a
manner that would, at least arguably, establish the ground to be a “different”
ground than the ones presented here. In addition, Patent Owner correctly
notes that Petitioner expressly preserves the right to make arguments
regarding the priority date of [Patent Owner’s] asserted patents in the district
court proceedings, which is indisputably a potential issue for the ’123 patent
in both proceedings.
This fourth Fintiv factor involves consideration of inefficiency
concerns and the possibility of conflicting decisions. Fintiv, Paper 11 at 12.
Therefore, “if the petition includes the same or substantially the same
claims, grounds, arguments, and evidence as presented in the parallel
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proceeding, this fact has favored denial.” Id. As discussed, there is
substantial overlap between the grounds asserted in the underlying litigation
and those asserted in the Petition, so that institution of an inter partes review
likely will result in duplicative efforts by the Board and the trial court as to
how the references teach limitations of the challenged claims. For these
reasons, we determine that this factor on balance favors the exercise of
discretionary denial.
E. Fintiv Factor 5: Whether Petitioner is the Defendant
in the Underlying
It is undisputable that Petitioner here is the defendant(s) in the
underlying litigation. See Pet. 74–75; Prelim. Resp. 5. Because there
appears to be overlapping issues that the trial court will likely analyze and
resolve for the same parties more than seven months before we would issues
a final written decision, this factor favors the exercise of discretionary denial
in this case.
F. Fintiv Factor 6: Other Considerations
Under the sixth Fintiv factor, which takes into account any other
relevant circumstances, Petitioner contends that this factor “favors institution
because the grounds in the petition provide a strong showing of
obviousness.” Pet. 73. Although we do not undertake here a full analysis of
the merits, our initial inspection of the record and the parties’ arguments
suggest that there is a reasonable likelihood that Petitioner would prevail
with respect to at least one of the claims challenged in the Petition. In a
balanced assessment of the relevant evidence of record, and in view of the
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possible strength of Petitioner’s showing on the present record, this factor is
neutral.
G. Fintiv Conclusion
Based on the particular circumstances of this case, we determine that
instituting an inter partes review would be an inefficient use of Board
resources. As discussed above, the trial in the underlying litigation is
currently scheduled to begin in about four months and may conclude several
months before we would reach a final decision in this proceeding.
Furthermore, the record shows that Petitioner delayed filing the Petition
without any excuse for the delay and, therefore, bears significant
responsibility for the fact that the district court and the parties have
expended effort in preparing for the upcoming trial that will address issues
that substantially overlap with those raised in the Petition. On balance, after
a holistic consideration of the relevant facts, we conclude that efficiency and
integrity of the system are best served by denying institution. Thus, we
exercise our discretion under § 314(a) to deny institution of inter partes
review.
IV. ORDER
Accordingly, it is
ORDERED that the Petition is denied; and
FURTHER ORDERED that no inter partes review is instituted.

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For PETITIONER:
Jonathan Tuminaro
Robert E. Sokohl
Dohm Chankong
Steven M. Pappas
Tyler Dutton
STERNE, KESSLER, GOLDSTEIN & FOX, P.L.L.C.
jtuminar-PTAB@sternekessler.com
rsokohl-PTAB@sternekessler.com
dchankong-PTAB@sternekessler.com
spappas-PTAB@sternekessler.com
tdutton-PTAB@sternekessler.com
Neil P. Sirota
Margaret M. Welsh
BAKER BOTTS L.L.P.
neil.sirota@bakerbotts.com
margaret.welsh@bakerbotts.com

For PATENT OWNER:
Vincent J. Rubino, III
Peter Lambrianakos
Enrique W. Iturralde
BROWN RUDNICK LLP
vrubino@brownrudnick.com
plambrianakos@brownrudnick.com
eiturralde@brownrudnick.com