International Business Machines Corporation v. Zynga Inc.

District Court, D. Delaware·Decided August 29, 2024·No. 1:22-cv-00590·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE INTERNATIONAL BUSINESS MACHINES CORP., Plaintiff,

Vv. Civil Action No. 22-590-GBW ZYNGA INC., Defendant.

MEMORANDUM ORDER Having reviewed the proposed joint pretrial order (D.I. 485) submitted by Plaintiff International Business Machines Corp. (“IBM”) and Defendant Zynga Inc. (“Zynga”), IT IS HEREBY ORDERED that: 1. IBM’s motion in limine (“MIL”) #1 seeks to preclude Zynga from offering argument, evidence, or testimony regarding the equitable defenses of double patenting, prosecution history estoppel, inequitable conduct, collateral estoppel, prosecution laches, unclean hands, waiver, and equitable estoppel. D.I. 485, Ex. K, IBM’s MIL #1. While IBM seeks to prevent Zynga from raising its obviousness-type double patenting (“OTDP”) defense during the jury trial, OTDP “is an issue of law premised on underlying factual inquiries.” Allergan USA, Inc. v. MSN Lab’ys Priv. Ltd., No. 2024-1061, 2024 WL 3763599, at *4 (Fed. Cir. Aug. 13, 2024). The relevant “factual inquiries” relate to whether the asserted claims are patentably distinct over the reference claims. Id. According to IBM, several legal complexities bar Zynga from pursuing an OTDP defense, because “a patent must be earlier-filed to be available as an OTDP reference.” D.I. 485, Ex. K,

IBM’s MIL #1 at 1-2 (quoting Acadia Pharms Inc. v. Aurobindo Pharma Ltd., No. CV 20-985- GBW, 2023 WL 8803448, at *8 (D. Del. Dec. 13, 2023)); see also Allergan, 2024 WL 3763599, at *6-7 (holding that a “first-filed, first-issued, later-expiring claim cannot be invalidated by a later- filed, later-issued, earlier-expiring reference claim.”). Yet, IBM’s MIL #1 is not a proper vehicle to request resolution of the alleged legal issues with Zynga’s OTDP defense. See D.I. 485, Ex. K, IBM’s MIL #2 at 2 (“[T]he Court should evaluate IBM’s conduct within that complex legal framework and reject the defense .. . “). Insofar as IBM maintains that “the asserted claims of the ’849 patent are patentably distinct over the reference claims of the ’209 patent,” this narrow question is a question of fact for the jury to decide, and the Court agrees with Zynga that the jury, at the very least, can issue an advisory verdict that the parties can challenge after trial. See D.I.494. Zynga also contends that certain portions of its equitable defenses may be relevant to issues that the jury will decide, including validity and willfulness. D.I. 485, Ex. K, Zynga’s Opposition to IBM’s MIL #1, at 2. Zynga contends, for example, that the jury can lawfully consider whether the Patent Office had all the information that was presented to the jury when deciding validity. Jd. at 3 (citing Microsoft Corp. v. i4i Ltd. P’ship, 564 U.S. 91, 111 (2011)). Similarly, Zynga contends that evidence of waiver may be relevant to Zynga’s willfulness defense, as the period between the failed licensing discussions and the suit purportedly supports Zynga’s claim that it does not infringe IBM’s patents. D.I. 586, Ex. K, Zynga’s Opposition to IBM’s MIL #1, at 3. Lastly, Zynga argues that evidence related to collateral estoppel may be relevant to the credibility of IBM’s expert witness, given that any contradictions between the expert’s trial testimony and the expert’s testimony in past cases may reduce his credibility in the eyes of the jury. Jd. The Court will reserve judgment on these uses of evidence related to equitable defenses, as IBM has not demonstrated that the evidence is substantially more prejudicial than probative. See Fed. R. Evid.

403. Certain evidence may be relevant to both an equitable defense and an issue for the jury, and the Court will consider usage of such evidence on a case-by-case basis at trial. Thus, IBM’s MIL #1 is DENIED as to evidence relating to obviousness type double patenting and DENIED WITHOUT PREJUDICE as to all other evidence. 2. IBM’s MIL #2 seeks to exclude any evidence, testimony, or argument concerning the opinions of other Courts on the Asserted Patents under Rule 403. D.I. 485, Ex. K, IBM’s MIL #2. IBM contends that the Court should exclude any evidence concerning prior dispositive decisions, prior Markman decisions, and arguments related to those decisions. /d at 1. Courts routinely exclude evidence and argumentation relating to prior litigation because the risk of unfair prejudice substantially outweighs the probative value of any evidence. See Helios Software, LLC et al. v. SpectorSoftCorp.,2015 WL 3653098, at *1 (D. Del. 2015); Sunoco Partners Marketing & Terminals LP v. Powder Springs Logistics, LLC, No. 1:17-cv-01390LPS, D.I. 719, at 3 (D. Del. Nov. 10, 2021); WL. Gore & Assocs., Inc. v. C.R. Bard, Inc., No. 1:11-cv-00515-LPS-CJB, D.I. 502 at 114:4-11 (D. Del. Dec. 15, 2015). Evidence of a prior summary judgment ruling on unrelated products, for instance, can be highly confusing to the jury and often has very little relevance to the relevant case. Thus, the Court will not permit either party to introduce such evidence to the jury. Zynga also contends that it can rely on the Markman orders of other courts to support the plain and ordinary meaning of unconstrued terms. D.I. 485, Ex. K, Zynga’s Opposition to IBM’s MIL #2, at 2. Yet, the parties cannot argue claim construction to the jury, and Zynga’s introduction of constructions made by other courts would be highly confusing and would impede on this Court’s obligation to provide the jury with constructions of disputed claim terms. CtyoLogix Corp. v. Ventana Med. Sys., Inc., 424 F.3d 1168, 1172 (Fed. Cir. 2005). Accordingly, the Court will not permit testimony from either expert regarding terms not construed

in this case. Lastly, Zynga seeks to introduce IBM’s past statements about the scope of the asserted claims that were made during a Markman hearing in a different case. D.I. 485, Zynga’s Opposition to IBM’s MIL #2, at 2. If Zynga believes that IBM’s past statements are relevant to the scope of a claim, however, this is a claim construction argument for the Court, not the jury. See O2 Micro Int'l Ltd. v. Beyond Innovation Tech. Co., 521 F.3d 1351, 1360 (Fed. Cir. 2008). Thus, Zynga may not introduce past statements made by IBM during a Markman hearing to impeach IBM’s counsel at trial. Zynga suggests that IBM should therefore be precluded from referencing a favorable jury verdict. D.I. 485, Ex. K, Zynga’s Opposition to IBM’s MIL #2, at 1. The Court agrees that references to any prior verdicts should be appropriately limited, but a favorable jury verdict that was shared pre-suit with Zynga may be relevant to willfulness and thus should not be excluded entirely. Sprint Commc’n Co., L.P. v. Time Warner Cable, Inc., 760 F. App’x 977, 980-82 (Fed. Cir. 2019). Thus, IBM’s MIL #2 is GRANTED, and neither side will be allowed to present collateral orders from other courts. 3. IBM’s MIL #3 seeks to exclude any evidence, argument, or reference to comparisons of the accused products to the specification or figures in the asserted patents to argue non- infringement or invalidity. D.I. 485, Ex. K, IBM’s MIL #3. Notably, “the only proper comparison is with the claims of the patent.” Zenith Lab’ys, Inc. v. Bristol-Myers Squibb Co., 19 F. 3d 1418, 1423 (Fed. Cir. 1994); see also Zenith Elecs. Corp. v PDI Comme'n Sys., Inc., 522 F.3d 1348, 1363 (Fed. Cir. 2008) (similar for invalidity). This means that infringement cannot determined by comparing an accused product “with a preferred embodiment described in the specification.” SRI Int’l v. Matsushita Elec. Corp.

Free access — add to your briefcase to read the full text and ask questions with AI

International Business Machines Corporation v. Zynga Inc., (D. Del. 2024).

International Business Machines Corporation v. Zynga Inc. (International Business Machines Corporation v. Zynga Inc.) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related