`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`SYNOPSYS, INC.
`Petitioner
`
`v.
`
`Patent of MENTOR GRAPHICS CORPORATION
`Patent Owner
`
`____________
`
`Case IPR2012-00042 (SCM)
`Patent 6,240,376 B1
`
`
`
`
`
`
`
`
`PETITIONER’S OBJECTIONS TO EXHIBITS IN PATENT OWNER’S
`REPLY IN SUPPORT OF ITS SUBSTITUTE MOTION TO AMEND
`
`
`
`1
`
`SYNOPSYS 1022 Synopsys v. Mentor, IPR2012-00042
`
`
`
`PETITIONER’S OBJECTIONS TO EXHIBITS IN PATENT OWNER’S
`REPLY IN SUPPORT OF ITS SUBSTITUTE MOTION TO AMEND
`
`Petitioner Synopsys, Inc. hereby objects pursuant to 37 C.F.R. § 42.64(b) to
`
`
`
`Exhibits 2030, 2031, and 2033 submitted by Patent Owner in its Reply in Support of
`
`its Substitute Motion to Amend (“Reply”). Patent Owner objects to these exhibits as
`
`irrelevant to the issues before the Board.
`
`Neither Ex. 2030 nor 2031 are even referenced in Patent Owner’s Reply.
`
`Moreover, they pertain to paragraph 33 of Dr. Hutchings’ declaration which he
`
`deleted of his own accord during his deposition. See Ex. 2032 at 27:24-28:11.
`
`Patent Owner submitted Ex. 2033 to attempt to swear behind the Boubezari
`
`reference. However, as noted in Petitioner’s Opposition (paper 35 at 9) “whether
`
`Boubezari qualifies as prior art is irrelevant here because Petitioner is relying on
`
`Boubezari to show the level of knowledge and skill in the art at the time of the
`
`invention, not as a prior art reference to be combined with Gregory.” Thus whether
`
`or not Patent Owner can “swear behind” Boubezari is irrelevant and so is Ex. 2033.
`
`We believe the Board already addressed this issue when it denied Patent Owner’s
`
`request for extra pages.
`
`2
`
`2
`
`SYNOPSYS 1022 Synopsys v. Mentor, IPR2012-00042
`
`
`
`Dated:
`
`October 5, 2013
`
`
`
`
`
`Respectfully submitted,
`
`By: /Travis Jensen/
`
`Travis Jensen
`CA Bar No. 259925
`Registration No. 60,087
`tjensen@orrick.com
`ORRICK, HERRINGTON, &
`SUTCLIFFE LLP
`1000 Marsh Road
`Menlo Park, CA 94025-1015
`Tel: 650-614-7400
`Fax: 650-614-7401
`
`William H. Wright
`CA Bar No. 161580
`Registration No. 36,312
`wwright@orrick.com
`ORRICK, HERRINGTON, &
`SUTCLIFFE LLP
`777 South Figueroa Street, Suite 3200
`Los Angeles, California 90017
`Tel: 213-629-2020
`Fax: 213-612-2499
`
`Attorneys for Petitioner,
`
`Synopsys, Inc.
`
`3
`
`3
`
`SYNOPSYS 1022 Synopsys v. Mentor, IPR2012-00042
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies e-mail service pursuant to 37 C.F.R. § 42.6(e) and
`
`agreement of counsel of a true copy of the foregoing PETITIONER’S
`
`OBJECTIONS TO EXHIBITS IN PATENT OWNER’S REPLY IN SUPPORT
`
`OF ITS SUBSTITUTE MOTION TO AMEND to counsel of record for Patent
`
`Owner as follows:
`
`Christopher L. McKee and Michael S. Cuviello
`
`cmckee@bannerwitcoff.com; mcuviello@bannerwitcoff.com
`
`Mentoripr@bannerwitcoff.com
`
`Dated: October 5, 2013
`
`By: /s/ Travis Jensen
`
`
`
`
`
` Travis Jensen
`
`4
`
`4
`
`SYNOPSYS 1022 Synopsys v. Mentor, IPR2012-00042
`
`
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